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TREAS/IRS | RIN: 1545-BI99 | Publication ID: Spring 2010 |
Title: ●Application of Section 108(i) to Partnerships and S Corporations | |
Abstract: Section 108(i), added by section 1231 of the American Recovery and Reinvestment Tax Act of 2009, allows a taxpayer to elect irrevocably to defer COD income arising from reacquiring an applicable debt instrument after December 31, 2008, and before January 1, 2011. These regulations provide rules for partnerships and S Corporations that make an election under section 108(i). | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: First time published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: Undetermined |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 26 USC 108 PL 111-5, sec 2131 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-144762-09 Drafting attorneys: Megan A. Stoner (202) 622-3070 and Joseph R. Worst (202) 622-3070 Reviewing attorney: Mary Beth Carchia (202) 622-3070 Treasury attorney: Emily Lam (202) 622-5293 CC: PSI | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-BJ00 | |
Agency Contact: Megan A. Stoner General Attorney (Tax) Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5315, Washington, DC 20224 Phone:202 622-3070 Fax:202 622-4804 Email: megan.a.stoner@irscounsel.treas.gov Joseph R. Worst Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5026, Washington, DC 20224 Phone:202 317-5279 Fax:202 317-6730 Email: joseph.r.worst@irscounsel.treas.gov |