Author Tax Policy Group, Deloitte Tax LLP
IRS Ruling Describes Treatment of Fund of Hedge Funds Expenses – The IRS issued a revenue ruling addressing the treatment of expenses incurred by a fund of funds in connection with its activities of investing in a series of underlying funds, which were themselves managed by third parties. Senate Clears Comprehensive Housing Stimulus Legislation – The Senate approved comprehensive housing stimulus legislation with a 10-year, $14.5 billion tax incentives package that is partially offset by revenue raisers, including a proposal to require information reporting on credit card transactions. Regs Provide Deemed Election to Deduct Start-Up or Organizational Expenditures – The IRS released final, temporary and proposed regulations on elections to deduct start-up expenditures under section 195, corporate organizational expenditures under section 248 and partnership organizational expenditures under section 709. New Regs Shorten Extended Filing Period for Certain Passthrough Returns – Recently released final, temporary and proposed regulations change the extended due date on certain passthrough business returns, reducing the extension period from six to five months. Baucus to Introduce New Extenders, AMT Legislation; Timing Uncertain – Senate Finance Committee Chairman Max Baucus, D-Mont., told reporters that he intends to introduce revised legislation to extend expired or expiring tax provisions and patch the individual alternative minimum tax, but was unclear on his timetable. House-Approved Pension Technical Corrections Bill Includes Asset Smoothing Provision – The House approved a pension technical corrections bill that includes a clarification of Congress's intent to preserve two-year asset smoothing in the calculation of the value of pension assets.
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