CFR Title 26 Internal Revenue

CFR Title 26 – Internal Revenue

CFR DataTable of FEDERAL REGISTER Activity

PublishedTypeAgenciesNameTitleExcerptFRDocPDFHTMLAbstract
PublishedTypeAgenciesNameTitleExcerptFRDocPDFHTMLAbstract
2018-09-11RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSubstantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions; CorrectionThis document contains corrections to final regulations (TD 9836) that were published in the Federal Register on Monday, July 30, 2018. The final regulations provide guidance concerning substantiation and reporting requirements for cash and noncash...2018-19679"https://www.gpo.gov/fdsys/pkg/FR-2018-09-11/pdf/2018-19679.pdfhttps://www.federalregister.gov/documents/2018/09/11/2018-19679/substantiation-and-reporting-requirements-for-cash-and-noncash-charitable-contribution-deductionsThis document contains corrections to final regulations (TD 9836) that were published in the Federal Register on Monday, July 30, 2018. The final regulations provide guidance concerning substantiation and reporting requirements for cash and noncash charitable contributions.
2018-08-27Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentContributions in Exchange for State or Local Tax CreditsThis document contains proposed amendments to regulations under section 170 of the Internal Revenue Code (Code). The proposed amendments provide rules governing the availability of charitable contribution deductions under section 170 when a taxpayer...2018-18377"https://www.gpo.gov/fdsys/pkg/FR-2018-08-27/pdf/2018-18377.pdfhttps://www.federalregister.gov/documents/2018/08/27/2018-18377/contributions-in-exchange-for-state-or-local-tax-creditsThis document contains proposed amendments to regulations under section 170 of the Internal Revenue Code (Code). The proposed amendments provide rules governing the availability of charitable contribution deductions under section 170 when a taxpayer receives or expects to receive a corresponding state or local tax credit. This document also proposes amendments to the regulations under section 642(c) to apply similar rules to payments made by a trust or decedent's estate. This document provides notification of a public hearing on these proposed regulations.
2018-08-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentProposed Removal of Temporary Regulations on a Partner's Share of a Partnership Liability for Disguised Sale Purposes; Hearing CancellationThis document cancels a public hearing on proposed regulations concerning how partnership liabilities are allocated for disguised sale purposes.2018-17792"https://www.gpo.gov/fdsys/pkg/FR-2018-08-17/pdf/2018-17792.pdfhttps://www.federalregister.gov/documents/2018/08/17/2018-17792/proposed-removal-of-temporary-regulations-on-a-partners-share-of-a-partnership-liability-forThis document cancels a public hearing on proposed regulations concerning how partnership liabilities are allocated for disguised sale purposes.
2018-08-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCentralized Partnership Audit RegimeThis document contains proposed regulations implementing the centralized partnership audit regime. This document withdraws and reproposes certain portions of proposed regulations implementing the centralized partnership audit regime that have not been...2018-17614"https://www.gpo.gov/fdsys/pkg/FR-2018-08-17/pdf/2018-17614.pdfhttps://www.federalregister.gov/documents/2018/08/17/2018-17614/centralized-partnership-audit-regimeThis document contains proposed regulations implementing the centralized partnership audit regime. This document withdraws and reproposes certain portions of proposed regulations implementing the centralized partnership audit regime that have not been finalized to reflect the changes made by the Technical Corrections Act of 2018, contained in Title II of the Consolidated Appropriations Act of 2018 (TTCA). The proposed regulations affect partnerships with respect to partnership taxable years beginning after December 31, 2017, as well as partnerships that make the election under the Bipartisan Budget Act of 2015 (BBA), to apply the centralized partnership audit regime to partnership taxable years beginning on or after November 2, 2015 and before January 1, 2018.
2018-08-16Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentQualified Business Income DeductionThis document contains proposed regulations concerning the deduction for qualified business income under section 199A of the Internal Revenue Code (Code). The regulations will affect individuals, partnerships, S corporations, trusts, and estates...2018-17276"https://www.gpo.gov/fdsys/pkg/FR-2018-08-16/pdf/2018-17276.pdfhttps://www.federalregister.gov/documents/2018/08/16/2018-17276/qualified-business-income-deductionThis document contains proposed regulations concerning the deduction for qualified business income under section 199A of the Internal Revenue Code (Code). The regulations will affect individuals, partnerships, S corporations, trusts, and estates engaged in domestic trades or businesses. The proposed regulations also contain an anti- avoidance rule under section 643 of the Code to treat multiple trusts as a single trust in certain cases. This document also provides notice of a public hearing on these proposed regulations.
2018-08-09RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPartnership Representative Under the Centralized Partnership Audit Regime and Election To Apply the Centralized Partnership Audit RegimeThis document contains final regulations regarding the designation and authority of the partnership representative under the centralized partnership audit regime, which was enacted into law on November 2, 2015 by section 1101 of the Bipartisan Budget...2018-17002"https://www.gpo.gov/fdsys/pkg/FR-2018-08-09/pdf/2018-17002.pdfhttps://www.federalregister.gov/documents/2018/08/09/2018-17002/partnership-representative-under-the-centralized-partnership-audit-regime-and-election-to-apply-theThis document contains final regulations regarding the designation and authority of the partnership representative under the centralized partnership audit regime, which was enacted into law on November 2, 2015 by section 1101 of the Bipartisan Budget Act of 2015 (BBA). These final regulations affect partnerships for taxable years beginning after December 31, 2017. This document also contains final regulations and removes temporary regulations regarding the election to apply the centralized partnership audit regime to partnership taxable years beginning after November 2, 2015 and before January 1, 2018 under section 1101(g)(4) of the BBA. These final regulations affect partnerships for taxable years beginning after November 2, 2015 and before January 1, 2018.
2018-08-09Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Regarding the Transition Tax Under Section 965 and Related ProvisionsThis document contains proposed regulations implementing section 965 of the Internal Revenue Code (``Code'') as amended by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations would affect United States persons...2018-16476"https://www.gpo.gov/fdsys/pkg/FR-2018-08-09/pdf/2018-16476.pdfhttps://www.federalregister.gov/documents/2018/08/09/2018-16476/guidance-regarding-the-transition-tax-under-section-965-and-related-provisionsThis document contains proposed regulations implementing section 965 of the Internal Revenue Code (``Code'') as amended by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations would affect United States persons with direct or indirect ownership interests in certain foreign corporations.
2018-08-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAdditional First Year Depreciation DeductionThis document contains proposed regulations that provide guidance regarding the additional first year depreciation deduction under section 168(k) of the Internal Revenue Code (Code). These proposed regulations reflect changes made by the Tax Cuts and...2018-16716"https://www.gpo.gov/fdsys/pkg/FR-2018-08-08/pdf/2018-16716.pdfhttps://www.federalregister.gov/documents/2018/08/08/2018-16716/additional-first-year-depreciation-deductionThis document contains proposed regulations that provide guidance regarding the additional first year depreciation deduction under section 168(k) of the Internal Revenue Code (Code). These proposed regulations reflect changes made by the Tax Cuts and Jobs Act. These proposed regulations affect taxpayers who deduct depreciation for qualified property acquired and placed in service after September 27, 2017.
2018-08-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExtension of Time To File Certain Information ReturnsThis document contains final regulations providing rules regarding the automatic and non-automatic extension of time to file certain information returns. These changes are being implemented to accelerate the filing of the Form W-2 series (except Form...2018-16717"https://www.gpo.gov/fdsys/pkg/FR-2018-08-03/pdf/2018-16717.pdfhttps://www.federalregister.gov/documents/2018/08/03/2018-16717/extension-of-time-to-file-certain-information-returnsThis document contains final regulations providing rules regarding the automatic and non-automatic extension of time to file certain information returns. These changes are being implemented to accelerate the filing of the Form W-2 series (except Form W-2G) and forms that report nonemployee compensation (currently Form 1099-MISC with information in box 7) so they are available earlier in the filing season for use in the IRS's identity theft and refund fraud detection processes. In addition, these final regulations update the list of information returns subject to the rules regarding extensions of time to file. These regulations affect filers requesting an extension of time to file the affected information returns.
2018-08-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentShort-Term, Limited-Duration InsuranceThis final rule amends the definition of short-term, limited- duration insurance for purposes of its exclusion from the definition of individual health insurance coverage. This action is being taken to lengthen the maximum duration of short-term,...2018-16568"https://www.gpo.gov/fdsys/pkg/FR-2018-08-03/pdf/2018-16568.pdfhttps://www.federalregister.gov/documents/2018/08/03/2018-16568/short-term-limited-duration-insuranceThis final rule amends the definition of short-term, limited- duration insurance for purposes of its exclusion from the definition of individual health insurance coverage. This action is being taken to lengthen the maximum duration of short-term, limited-duration insurance, which will provide more affordable consumer choices for health coverage.
2018-07-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSubstantiation and Reporting Requirements for Cash and Noncash Charitable Contribution DeductionsThese final regulations provide guidance concerning substantiation and reporting requirements for cash and noncash charitable contributions. The final regulations reflect the enactment of provisions of the American Jobs Creation Act of 2004 and the...2018-15734"https://www.gpo.gov/fdsys/pkg/FR-2018-07-30/pdf/2018-15734.pdfhttps://www.federalregister.gov/documents/2018/07/30/2018-15734/substantiation-and-reporting-requirements-for-cash-and-noncash-charitable-contribution-deductionsThese final regulations provide guidance concerning substantiation and reporting requirements for cash and noncash charitable contributions. The final regulations reflect the enactment of provisions of the American Jobs Creation Act of 2004 and the Pension Protection Act of 2006. These regulations provide guidance to individuals, partnerships, and corporations that make charitable contributions.
2018-07-20RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinitions of Qualified Matching Contributions and Qualified Nonelective ContributionsThis document contains final regulations that amend the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations regarding certain qualified retirement plans that contain cash or deferred...2018-15495"https://www.gpo.gov/fdsys/pkg/FR-2018-07-20/pdf/2018-15495.pdfhttps://www.federalregister.gov/documents/2018/07/20/2018-15495/definitions-of-qualified-matching-contributions-and-qualified-nonelective-contributionsThis document contains final regulations that amend the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations regarding certain qualified retirement plans that contain cash or deferred arrangements under section 401(k) or that provide for matching contributions or employee contributions under section 401(m). Under these regulations, an employer contribution to a plan may be a QMAC or QNEC if it satisfies applicable nonforfeitability requirements and distribution limitations at the time it is allocated to a participant's account, but need not meet these requirements or limitations when it is contributed to the plan. These regulations affect participants in, beneficiaries of, employers maintaining, and administrators of tax-qualified plans that contain cash or deferred arrangements or provide for matching contributions or employee contributions.
2018-07-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTax Return Preparer Due Diligence Penalty Under Section 6695(g)This document contains proposed regulations that amend portions of previously proposed regulations related to the tax return preparer penalty under section 6695(g) of the Internal Revenue Code (Code). These amendments to the previously proposed...2018-15351"https://www.gpo.gov/fdsys/pkg/FR-2018-07-18/pdf/2018-15351.pdfhttps://www.federalregister.gov/documents/2018/07/18/2018-15351/tax-return-preparer-due-diligence-penalty-under-section-6695gThis document contains proposed regulations that amend portions of previously proposed regulations related to the tax return preparer penalty under section 6695(g) of the Internal Revenue Code (Code). These amendments to the previously proposed regulations are necessary to implement a recent law change that expands the scope of the tax return preparer due diligence penalty under section 6695(g) so that it applies with respect to eligibility to file a return or claim for refund as head of household. The proposed regulations affect tax return preparers.
2018-07-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentFiling Requirements for Information Returns Required on Magnetic Media (Electronically); CorrectionThis document contains a correction to notice of proposed rulemaking (REG-102951-16) that was published in the Federal Register on Thursday, May 31, 2018 (83 FR 24948). The proposed regulations are relating to amending rules for determining whether...2018-15164"https://www.gpo.gov/fdsys/pkg/FR-2018-07-17/pdf/2018-15164.pdfhttps://www.federalregister.gov/documents/2018/07/17/2018-15164/filing-requirements-for-information-returns-required-on-magnetic-media-electronically-correctionThis document contains a correction to notice of proposed rulemaking (REG-102951-16) that was published in the Federal Register on Thursday, May 31, 2018 (83 FR 24948). The proposed regulations are relating to amending rules for determining whether information returns must be filed by using magnetic media (electronically).
2018-07-12RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related TransactionsThis document contains final regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations...2018-14693"https://www.gpo.gov/fdsys/pkg/FR-2018-07-12/pdf/2018-14693.pdfhttps://www.federalregister.gov/documents/2018/07/12/2018-14693/inversions-and-related-transactionsThis document contains final regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. This document finalizes proposed regulations, and removes temporary regulations, published on April 8, 2016.
2018-06-26Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Non-Government Attorneys Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) Contractor; HearingThis document provides a notification of public hearing on proposed regulations relating to section 7602(a) of the Internal Revenue Code relating to administrative proceedings.2018-13695"https://www.gpo.gov/fdsys/pkg/FR-2018-06-26/pdf/2018-13695.pdfhttps://www.federalregister.gov/documents/2018/06/26/2018-13695/certain-non-government-attorneys-not-authorized-to-participate-in-examinations-of-books-andThis document provides a notification of public hearing on proposed regulations relating to section 7602(a) of the Internal Revenue Code relating to administrative proceedings.
2018-06-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentProposed Removal of Temporary Regulations on a Partner's Share of a Partnership Liability for Disguised Sale PurposesThis document contains proposed regulations concerning how partnership liabilities are allocated for disguised sale purposes. The proposed regulations, if finalized, would replace existing temporary regulations with final regulations that were in...2018-13129"https://www.gpo.gov/fdsys/pkg/FR-2018-06-19/pdf/2018-13129.pdfhttps://www.federalregister.gov/documents/2018/06/19/2018-13129/proposed-removal-of-temporary-regulations-on-a-partners-share-of-a-partnership-liability-forThis document contains proposed regulations concerning how partnership liabilities are allocated for disguised sale purposes. The proposed regulations, if finalized, would replace existing temporary regulations with final regulations that were in effect prior to the temporary regulations. This document also partially withdraws proposed regulations cross-referencing the temporary regulations. These regulations affect partnerships and their partners. Finally, this document provides notice of a public hearing on these proposed regulations.
2018-06-12Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Investment Restrictions on Tax-Exempt BondsThis document contains proposed regulations regarding the arbitrage investment restrictions under section 148 of the Internal Revenue Code (Code) applicable to tax-exempt bonds and other tax- advantaged bonds issued by State and local governments. The...2018-12565"https://www.gpo.gov/fdsys/pkg/FR-2018-06-12/pdf/2018-12565.pdfhttps://www.federalregister.gov/documents/2018/06/12/2018-12565/arbitrage-investment-restrictions-on-tax-exempt-bondsThis document contains proposed regulations regarding the arbitrage investment restrictions under section 148 of the Internal Revenue Code (Code) applicable to tax-exempt bonds and other tax- advantaged bonds issued by State and local governments. The proposed regulations would clarify existing regulations regarding the definition of ``investment-type property'' covered by arbitrage restrictions by expressly providing an exception for investments in capital projects that are used in furtherance of the public purposes of the bonds. The proposed regulations affect State and local governmental issuers of these bonds and potential investors in capital projects financed with these bonds.
2018-06-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPartnership Transactions Involving Equity Interests of a PartnerThis document contains final regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner or certain related entities. This document also contains...2018-12407"https://www.gpo.gov/fdsys/pkg/FR-2018-06-08/pdf/2018-12407.pdfhttps://www.federalregister.gov/documents/2018/06/08/2018-12407/partnership-transactions-involving-equity-interests-of-a-partnerThis document contains final regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner or certain related entities. This document also contains final regulations that allow consolidated group members that are partners in the same partnership to aggregate their bases in stock distributed by the partnership for the purpose of limiting the application of rules that might otherwise cause basis reduction or gain recognition. This document also contains final regulations that may also require certain corporations that engage in gain elimination transactions to reduce the basis of corporate assets or to recognize gain. These final regulations affect partnerships and their partners.
2018-05-31Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentFiling Requirements for Information Returns Required on Magnetic Media (Electronically)This document contains proposed regulations amending the rules for determining whether information returns must be filed using magnetic media (electronically). The proposed regulations would require that all information returns, regardless of type, be...2018-11749"https://www.gpo.gov/fdsys/pkg/FR-2018-05-31/pdf/2018-11749.pdfhttps://www.federalregister.gov/documents/2018/05/31/2018-11749/filing-requirements-for-information-returns-required-on-magnetic-media-electronicallyThis document contains proposed regulations amending the rules for determining whether information returns must be filed using magnetic media (electronically). The proposed regulations would require that all information returns, regardless of type, be taken into account to determine whether a person meets the 250-return threshold and, therefore, must file the information returns electronically. The proposed regulations also would require any person required to file information returns electronically to file corrected information returns electronically, regardless of the number of corrected information returns being filed. The proposed regulations will affect persons required to file information returns.
2018-05-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2018-11690"https://www.gpo.gov/fdsys/pkg/FR-2018-05-30/pdf/2018-11690.pdfhttps://www.federalregister.gov/documents/2018/05/30/2018-11690/income-taxes
2018-05-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentClarification of Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protections Under the Affordable Care ActOn November 18, 2015, the Departments of Labor, Health and Human Services, and the Treasury (the Departments) published a final rule in the Federal Register titled ``Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and...2018-09369"https://www.gpo.gov/fdsys/pkg/FR-2018-05-03/pdf/2018-09369.pdfhttps://www.federalregister.gov/documents/2018/05/03/2018-09369/clarification-of-final-rules-for-grandfathered-plans-preexisting-condition-exclusions-lifetime-andOn November 18, 2015, the Departments of Labor, Health and Human Services, and the Treasury (the Departments) published a final rule in the Federal Register titled ``Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protections Under the Affordable Care Act'' (the November 2015 final rule), regarding, in part, the coverage of emergency services by non-grandfathered group health plans and health insurance issuers offering non-grandfathered group or individual health insurance coverage, including the requirement that non-grandfathered group health plans and health insurance issuers offering non-grandfathered group or individual health insurance coverage limit cost-sharing for out-of-network emergency services and, as part of that rule, pay at least a minimum amount for out-of-network emergency services. The American College of Emergency Physicians (ACEP) filed a complaint in the United States District Court for the District of Columbia, which on August 31, 2017 granted in part and denied in part without prejudice ACEP's motion for summary judgment and remanded the case to the Departments to respond to the public comments from ACEP and others. In response, the Departments are issuing this notice of clarification to provide a more thorough explanation of the Departments' decision not to adopt recommendations made by ACEP and certain other commenters in the November 2015 final rule.
2018-04-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Guidance for Tax-Exempt Bonds; CorrectionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016. The final regulations are related to arbitrage restrictions under section 148 of the Internal Revenue Code...2018-06704"https://www.gpo.gov/fdsys/pkg/FR-2018-04-03/pdf/2018-06704.pdfhttps://www.federalregister.gov/documents/2018/04/03/2018-06704/arbitrage-guidance-for-tax-exempt-bonds-correctionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016. The final regulations are related to arbitrage restrictions under section 148 of the Internal Revenue Code applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments.
2018-03-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAllocation of Controlled Group Research CreditThis document contains final regulations relating to the allocation of the credit for increasing research activities (research credit) to corporations and trades or businesses under common control (controlled groups). This document also contains final...2018-06241"https://www.gpo.gov/fdsys/pkg/FR-2018-03-28/pdf/2018-06241.pdfhttps://www.federalregister.gov/documents/2018/03/28/2018-06241/allocation-of-controlled-group-research-creditThis document contains final regulations relating to the allocation of the credit for increasing research activities (research credit) to corporations and trades or businesses under common control (controlled groups). This document also contains final regulations relating to the allocation of the railroad track maintenance credit and the election for a reduced research credit.
2018-03-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Non-Government Attorneys Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) ContractorThis document contains proposed regulations to amend regulations under section 7602(a) of the Internal Revenue Code relating to administrative proceedings. Current regulations permit any person authorized to receive returns and return information under...2018-06242"https://www.gpo.gov/fdsys/pkg/FR-2018-03-28/pdf/2018-06242.pdfhttps://www.federalregister.gov/documents/2018/03/28/2018-06242/certain-non-government-attorneys-not-authorized-to-participate-in-examinations-of-books-andThis document contains proposed regulations to amend regulations under section 7602(a) of the Internal Revenue Code relating to administrative proceedings. Current regulations permit any person authorized to receive returns and return information under section 6103(n) and the regulations thereunder to receive and review summoned books, papers, and other data, and, in the presence and under the guidance of an IRS officer or employee, participate fully in the interview of a witness in a summons interview. These proposed regulations significantly narrow the scope of the current regulations by excluding non-government attorneys from receiving summoned books, papers, records, or other data or from participating in the interview of a witness summoned by the IRS to provide testimony under oath, with a limited exception. These proposed regulations affect taxpayers involved in a federal tax examination and other persons whose books and records or testimony are sought to be examined by the IRS under section 7602(a).
2018-03-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAllocation of Mortgage Insurance Premiums; CorrectionThis document contains corrections to final regulations (TD 9588) that were published in the Federal Register on Monday, May 7, 2012. The final regulations are related to allocate prepaid qualified mortgage insurance premiums to determine the amount of...2018-05011"https://www.gpo.gov/fdsys/pkg/FR-2018-03-13/pdf/2018-05011.pdfhttps://www.federalregister.gov/documents/2018/03/13/2018-05011/allocation-of-mortgage-insurance-premiums-correctionThis document contains corrections to final regulations (TD 9588) that were published in the Federal Register on Monday, May 7, 2012. The final regulations are related to allocate prepaid qualified mortgage insurance premiums to determine the amount of the prepaid premium that is treated as qualified residence interest each taxable year.
2018-03-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisclosure of Returns and Return Information in Connection With Written Contracts or Agreements for the Acquisition of Property or Services for Tax Administration PurposesThis document contains proposed regulations under section 6103(n) of the Internal Revenue Code (Code) to authorize the Department of State to disclose returns and return information to its contractors who assist the Department of State in carrying out...2018-04971"https://www.gpo.gov/fdsys/pkg/FR-2018-03-13/pdf/2018-04971.pdfhttps://www.federalregister.gov/documents/2018/03/13/2018-04971/disclosure-of-returns-and-return-information-in-connection-with-written-contracts-or-agreements-forThis document contains proposed regulations under section 6103(n) of the Internal Revenue Code (Code) to authorize the Department of State to disclose returns and return information to its contractors who assist the Department of State in carrying out its responsibilities under section 32101 of the Fixing America's Surface Transportation (FAST) Act. The FAST Act requires the IRS to notify the Department of State of certified seriously delinquent tax debts, and the Department of State procures services from outside contractors in connection with carrying out its responsibilities under the FAST Act.
2018-03-07RuleDEPARTMENT OF THE TREASURYTreasury DepartmentBalanced System for Measuring Organizational and Employee Performance Within the Internal Revenue ServiceThis document contains final regulations regarding management and personnel within the IRS. The final regulations relate to the ``employee satisfaction measures'' utilized by the IRS in its Balanced System for Measuring Organizational and Employee...2018-04231"https://www.gpo.gov/fdsys/pkg/FR-2018-03-07/pdf/2018-04231.pdfhttps://www.federalregister.gov/documents/2018/03/07/2018-04231/balanced-system-for-measuring-organizational-and-employee-performance-within-the-internal-revenueThis document contains final regulations regarding management and personnel within the IRS. The final regulations relate to the ``employee satisfaction measures'' utilized by the IRS in its Balanced System for Measuring Organizational and Employee Performance. These regulations affect internal operations of the IRS and the systems employed to evaluate the performance of organizations within the IRS and individuals employed by the IRS.
2018-02-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentHealth Insurance Providers FeeThis document contains final regulations that provide rules for the definition of a covered entity for purposes of the fee imposed by section 9010 of the Patient Protection and Affordable Care Act, as amended. The final regulations supersede and adopt...2018-03884"https://www.gpo.gov/fdsys/pkg/FR-2018-02-26/pdf/2018-03884.pdfhttps://www.federalregister.gov/documents/2018/02/26/2018-03884/health-insurance-providers-feeThis document contains final regulations that provide rules for the definition of a covered entity for purposes of the fee imposed by section 9010 of the Patient Protection and Affordable Care Act, as amended. The final regulations supersede and adopt the text of temporary regulations that provide rules for the definition of a covered entity. The final regulations affect persons engaged in the business of providing health insurance for United States health risks.
2018-02-21Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentShort-Term, Limited-Duration InsuranceThis rule contains proposals amending the definition of short- term, limited-duration insurance for purposes of its exclusion from the definition of individual health insurance coverage. This action is being taken to lengthen the maximum period of...2018-03208"https://www.gpo.gov/fdsys/pkg/FR-2018-02-21/pdf/2018-03208.pdfhttps://www.federalregister.gov/documents/2018/02/21/2018-03208/short-term-limited-duration-insuranceThis rule contains proposals amending the definition of short- term, limited-duration insurance for purposes of its exclusion from the definition of individual health insurance coverage. This action is being taken to lengthen the maximum period of short-term, limited- duration insurance, which will provide more affordable consumer choice for health coverage.
2018-02-15Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentEliminating Unnecessary Tax RegulationsPursuant to the policies stated in Executive Orders 13777 and 13789 (the executive orders), the Treasury Department and the IRS conducted a review of existing regulations, with the goal of reducing regulatory burden for taxpayers by revoking or...2018-02918"https://www.gpo.gov/fdsys/pkg/FR-2018-02-15/pdf/2018-02918.pdfhttps://www.federalregister.gov/documents/2018/02/15/2018-02918/eliminating-unnecessary-tax-regulationsPursuant to the policies stated in Executive Orders 13777 and 13789 (the executive orders), the Treasury Department and the IRS conducted a review of existing regulations, with the goal of reducing regulatory burden for taxpayers by revoking or revising existing tax regulations that meet the criteria set forth in the executive orders. This notice of proposed rulemaking proposes to streamline IRS regulations by removing 298 regulations that are no longer necessary because they do not have any current or future applicability under the Internal Revenue Code (Code) and by amending 79 regulations to reflect the proposed removal of the 298 regulations. The proposed removal and amendment of these regulations may affect various categories of taxpayers.
2018-02-02Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCentralized Partnership Audit Regime: Adjusting Tax AttributesThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015, which was enacted into law on November 2, 2015. The Bipartisan Budge Act repeals the current rules governing partnership audits and replaces...2018-01989"https://www.gpo.gov/fdsys/pkg/FR-2018-02-02/pdf/2018-01989.pdfhttps://www.federalregister.gov/documents/2018/02/02/2018-01989/centralized-partnership-audit-regime-adjusting-tax-attributesThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015, which was enacted into law on November 2, 2015. The Bipartisan Budge Act repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, determines, assesses and collects tax at the partnership level. These proposed regulations provide rules addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the centralized partnership audit regime.
2018-01-02RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElection Out of the Centralized Partnership Audit RegimeThis document contains final regulations regarding the implementation of certain portions of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules...2017-28398"https://www.gpo.gov/fdsys/pkg/FR-2018-01-02/pdf/2017-28398.pdfhttps://www.federalregister.gov/documents/2018/01/02/2017-28398/election-out-of-the-centralized-partnership-audit-regimeThis document contains final regulations regarding the implementation of certain portions of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. This document provides final regulations for electing out of the centralized partnership audit regime. The final regulations affect partnerships for taxable years beginning after December 31, 2017.
2017-12-27RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Transactions in Which Federal Financial Assistance Is Provided; CorrectionThis document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend...2017-27863"https://www.gpo.gov/fdsys/pkg/FR-2017-12-27/pdf/2017-27863.pdfhttps://www.federalregister.gov/documents/2017/12/27/2017-27863/treatment-of-transactions-in-which-federal-financial-assistance-is-provided-correctionThis document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance is provided to banks and domestic building and loan associations, and they clarify the federal income tax consequences of those transactions to banks, domestic building and loan associations, and related parties.
2017-12-27Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExclusion of Foreign Currency Gain or Loss Related to Business Needs From Foreign Personal Holding Company Income; Mark-to-Market Method of Accounting for Section 988 Transactions; CorrectionThis document contains corrections to the proposed regulations (REG-119514-15) that were published in the Federal Register on Tuesday, December 19, 2017. The proposed regulations provide guidance on the treatment of foreign currency gain or loss of a...2017-27865"https://www.gpo.gov/fdsys/pkg/FR-2017-12-27/pdf/2017-27865.pdfhttps://www.federalregister.gov/documents/2017/12/27/2017-27865/exclusion-of-foreign-currency-gain-or-loss-related-to-business-needs-from-foreign-personal-holdingThis document contains corrections to the proposed regulations (REG-119514-15) that were published in the Federal Register on Tuesday, December 19, 2017. The proposed regulations provide guidance on the treatment of foreign currency gain or loss of a controlled foreign corporation (CFC) under the business needs exclusion from foreign personal holding company income (FPHCI). The proposed regulations also provide an election for a taxpayer to use a mark-to-market method of accounting for foreign currency gain or loss attributable to section 988 transactions. In addition, the proposed regulations permit the controlling United States shareholders of a CFC to automatically revoke certain elections concerning the treatment of foreign currency gain or loss.
2017-12-27RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Transactions in Which Federal Financial Assistance Is Provided; CorrectionThis document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend...2017-27862"https://www.gpo.gov/fdsys/pkg/FR-2017-12-27/pdf/2017-27862.pdfhttps://www.federalregister.gov/documents/2017/12/27/2017-27862/treatment-of-transactions-in-which-federal-financial-assistance-is-provided-correctionThis document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance is provided to banks and domestic building and loan associations, and they clarify the federal income tax consequences of those transactions to banks, domestic building and loan associations, and related parties.
2017-12-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCentralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural ProvisionsThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and...2017-27071"https://www.gpo.gov/fdsys/pkg/FR-2017-12-19/pdf/2017-27071.pdfhttps://www.federalregister.gov/documents/2017/12/19/2017-27071/centralized-partnership-audit-regime-rules-for-election-under-sections-6226-and-6227-including-rulesThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules addressing how pass-through partners take into account adjustments under the alternative to payment of the imputed underpayment described in section 6226 and under rules similar to section 6226 when a partnership files an administrative adjustment request under section 6227. To make corresponding changes, these proposed regulations amend portions of the previously proposed regulations under sections 6226 and 6227. Additionally, these proposed regulations provide rules regarding assessment and collection, penalties and interest, and period of limitations under the new centralized partnership audit regime. The proposed regulations also address the rules for seeking judicial review of partnership adjustments.
2017-12-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExclusion of Foreign Currency Gain or Loss Related to Business Needs From Foreign Personal Holding Company Income; Mark-to-Market Method of Accounting for Section 988 TransactionsThis document contains proposed regulations that provide guidance on the treatment of foreign currency gain or loss of a controlled foreign corporation (CFC) under the business needs exclusion from foreign personal holding company income (FPHCI). The...2017-27320"https://www.gpo.gov/fdsys/pkg/FR-2017-12-19/pdf/2017-27320.pdfhttps://www.federalregister.gov/documents/2017/12/19/2017-27320/exclusion-of-foreign-currency-gain-or-loss-related-to-business-needs-from-foreign-personal-holdingThis document contains proposed regulations that provide guidance on the treatment of foreign currency gain or loss of a controlled foreign corporation (CFC) under the business needs exclusion from foreign personal holding company income (FPHCI). The proposed regulations also provide an election for a taxpayer to use a mark-to- market method of accounting for foreign currency gain or loss attributable to section 988 transactions. In addition, the proposed regulations permit the controlling United States shareholders of a CFC to automatically revoke certain elections concerning the treatment of foreign currency gain or loss. The proposed regulations affect taxpayers and United States shareholders of CFCs that engage in transactions giving rise to foreign currency gain or loss under section 988 of the Internal Revenue Code (Code).
2017-11-30Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCentralized Partnership Audit Regime: International Tax RulesThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and...2017-25740"https://www.gpo.gov/fdsys/pkg/FR-2017-11-30/pdf/2017-25740.pdfhttps://www.federalregister.gov/documents/2017/11/30/2017-25740/centralized-partnership-audit-regime-international-tax-rulesThis document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules addressing how certain international rules operate in the context of the centralized partnership audit regime, including rules relating to the withholding of tax on foreign persons, withholding of tax to enforce reporting on certain foreign accounts, and the treatment of creditable foreign tax expenditures of a partnership.
2017-11-22RuleDEPARTMENT OF LABORLabor DepartmentExtension of Certain Time Frames for Employee Benefit Plans, Participants, and Beneficiaries Affected by Hurricane MariaThis document announces the extension of certain time frames under the Employee Retirement Income Security Act and the Internal Revenue Code for group health plans, disability and other welfare plans, pension plans, participants and beneficiaries of...2017-25332"https://www.gpo.gov/fdsys/pkg/FR-2017-11-22/pdf/2017-25332.pdfhttps://www.federalregister.gov/documents/2017/11/22/2017-25332/extension-of-certain-time-frames-for-employee-benefit-plans-participants-and-beneficiaries-affectedThis document announces the extension of certain time frames under the Employee Retirement Income Security Act and the Internal Revenue Code for group health plans, disability and other welfare plans, pension plans, participants and beneficiaries of these plans, and group health insurance issuers directly affected by Hurricane Maria.
2017-11-15RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property to Foreign Corporations; CorrectionThis document contains corrections to final regulations (TD 9803) that were published in the Federal Register on Friday, December 16, 2016. The final regulations are related to certain transfers of property by United States persons to foreign...2017-24687"https://www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-24687.pdfhttps://www.federalregister.gov/documents/2017/11/15/2017-24687/treatment-of-certain-transfers-of-property-to-foreign-corporations-correctionThis document contains corrections to final regulations (TD 9803) that were published in the Federal Register on Friday, December 16, 2016. The final regulations are related to certain transfers of property by United States persons to foreign corporations.
2017-10-26Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRevision of Regulations Under Chapter 3 Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons; CorrectionThis document corrects a correction to a notice of proposed rulemaking (REG-134247-16) that was published in the Federal Register on Friday, September 15, 2017. The notice of proposed rulemaking, published on January 6, 2017, under section 1441 of the...2017-22815"https://www.gpo.gov/fdsys/pkg/FR-2017-10-26/pdf/2017-22815.pdfhttps://www.federalregister.gov/documents/2017/10/26/2017-22815/revision-of-regulations-under-chapter-3-regarding-withholding-of-tax-on-certain-us-source-incomeThis document corrects a correction to a notice of proposed rulemaking (REG-134247-16) that was published in the Federal Register on Friday, September 15, 2017. The notice of proposed rulemaking, published on January 6, 2017, under section 1441 of the Internal Revenue Code of 1986 (Code), relates to withholding of tax on certain U.S. source income paid to foreign persons and requirements for certain claims for refund or credit of income tax made by foreign persons.
2017-10-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United States; CorrectionThis document contains corrections to final and temporary regulations (TD TD 9815), which were published in the Federal Register on Tuesday, January 24, 2017.2017-22830"https://www.gpo.gov/fdsys/pkg/FR-2017-10-26/pdf/2017-22830.pdfhttps://www.federalregister.gov/documents/2017/10/26/2017-22830/dividend-equivalents-from-sources-within-the-united-states-correctionThis document contains corrections to final and temporary regulations (TD TD 9815), which were published in the Federal Register on Tuesday, January 24, 2017.
2017-10-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentEstate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an InterestThis document withdraws proposed regulations concerning the estate, gift and generation-skipping transfer (GST) tax treatment of lapses of liquidation rights in family-controlled entities, as well as the valuation of interests in family-controlled...2017-22776"https://www.gpo.gov/fdsys/pkg/FR-2017-10-20/pdf/2017-22776.pdfhttps://www.federalregister.gov/documents/2017/10/20/2017-22776/estate-gift-and-generation-skipping-transfer-taxes-restrictions-on-liquidation-of-an-interestThis document withdraws proposed regulations concerning the estate, gift and generation-skipping transfer (GST) tax treatment of lapses of liquidation rights in family-controlled entities, as well as the valuation of interests in family-controlled corporations and partnerships for estate, gift, and GST tax purposes. Specifically, the proposed regulations would have treated certain lapses of liquidation rights as transfers occurring at death. The proposed regulations also addressed the treatment of restrictions on liquidation and withdrawal in determining the value of transferred interests in family-controlled entities. This withdrawal affects certain transferors of interests in corporations and partnerships.
2017-10-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Political SubdivisionThis document withdraws a notice of proposed rulemaking regarding the definition of a political subdivision for purposes of tax-exempt bonds.2017-22777"https://www.gpo.gov/fdsys/pkg/FR-2017-10-20/pdf/2017-22777.pdfhttps://www.federalregister.gov/documents/2017/10/20/2017-22777/definition-of-political-subdivisionThis document withdraws a notice of proposed rulemaking regarding the definition of a political subdivision for purposes of tax-exempt bonds.
2017-10-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Transactions in Which Federal Financial Assistance Is ProvidedThis document contains final regulations under section 597 of the Internal Revenue Code (Code). These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance (FFA)...2017-21129"https://www.gpo.gov/fdsys/pkg/FR-2017-10-19/pdf/2017-21129.pdfhttps://www.federalregister.gov/documents/2017/10/19/2017-21129/treatment-of-transactions-in-which-federal-financial-assistance-is-providedThis document contains final regulations under section 597 of the Internal Revenue Code (Code). These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance (FFA) is provided to banks and domestic building and loan associations, and they clarify the federal income tax consequences of those transactions to banks, domestic building and loan associations, and related parties. These regulations affect banks, domestic building and loan associations, and related parties.
2017-10-16Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExecutive Order 13789-Second Report to the President on Identifying and Reducing Tax Regulatory BurdensOn April 21, 2017, the President issued Executive Order 13789 (82 FR 19317), a directive designed to reduce tax regulatory burdens. The order directed the Secretary of the Treasury to identify significant tax regulations issued on or after January 1,...2017-22205"https://www.gpo.gov/fdsys/pkg/FR-2017-10-16/pdf/2017-22205.pdfhttps://www.federalregister.gov/documents/2017/10/16/2017-22205/executive-order-13789-second-report-to-the-president-on-identifying-and-reducing-tax-regulatoryOn April 21, 2017, the President issued Executive Order 13789 (82 FR 19317), a directive designed to reduce tax regulatory burdens. The order directed the Secretary of the Treasury to identify significant tax regulations issued on or after January 1, 2016, that impose an undue financial burden on U.S. taxpayers, add undue complexity to the Federal tax laws, or exceed the statutory authority of the Internal Revenue Service (IRS). In an interim Report to the President dated June 22, 2017, Treasury identified eight such regulations. Executive Order 13789 further directs the Secretary to submit to the President and publish in the Federal Register a report recommending specific actions to mitigate the burden imposed by regulations identified in the interim report. This Second Report sets forth the Secretary's recommendations.
2017-10-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMoral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care ActThe United States has a long history of providing conscience protections in the regulation of health care for entities and individuals with objections based on religious beliefs or moral convictions. These interim final rules expand exemptions to...2017-21852"https://www.gpo.gov/fdsys/pkg/FR-2017-10-13/pdf/2017-21852.pdfhttps://www.federalregister.gov/documents/2017/10/13/2017-21852/moral-exemptions-and-accommodations-for-coverage-of-certain-preventive-services-under-the-affordableThe United States has a long history of providing conscience protections in the regulation of health care for entities and individuals with objections based on religious beliefs or moral convictions. These interim final rules expand exemptions to protect moral convictions for certain entities and individuals whose health plans are subject to a mandate of contraceptive coverage through guidance issued pursuant to the Patient Protection and Affordable Care Act. These rules do not alter the discretion of the Health Resources and Services Administration, a component of the United States Department of Health and Human Services, to maintain the guidelines requiring contraceptive coverage where no regulatorily recognized objection exists. These rules also provide certain morally objecting entities access to the voluntary ``accommodation'' process regarding such coverage. These rules do not alter multiple other Federal programs that provide free or subsidized contraceptives for women at risk of unintended pregnancy.
2017-10-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReligious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care ActThe United States has a long history of providing conscience protections in the regulation of health care for entities and individuals with objections based on religious beliefs and moral convictions. These interim final rules expand exemptions to...2017-21851"https://www.gpo.gov/fdsys/pkg/FR-2017-10-13/pdf/2017-21851.pdfhttps://www.federalregister.gov/documents/2017/10/13/2017-21851/religious-exemptions-and-accommodations-for-coverage-of-certain-preventive-services-under-theThe United States has a long history of providing conscience protections in the regulation of health care for entities and individuals with objections based on religious beliefs and moral convictions. These interim final rules expand exemptions to protect religious beliefs for certain entities and individuals whose health plans are subject to a mandate of contraceptive coverage through guidance issued pursuant to the Patient Protection and Affordable Care Act. These rules do not alter the discretion of the Health Resources and Services Administration (HRSA), a component of the United States Department of Health and Human Services (HHS), to maintain the guidelines requiring contraceptive coverage where no regulatorily recognized objection exists. These rules also leave the ``accommodation'' process in place as an optional process for certain exempt entities that wish to use it voluntarily. These rules do not alter multiple other Federal programs that provide free or subsidized contraceptives for women at risk of unintended pregnancy.
2017-10-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReligious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed RulemakingIn this issue of the Federal Register, the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary regulations, as published in TD 9827, amends...2017-21856"https://www.gpo.gov/fdsys/pkg/FR-2017-10-13/pdf/2017-21856.pdfhttps://www.federalregister.gov/documents/2017/10/13/2017-21856/religious-exemptions-and-accommodations-for-coverage-of-certain-preventive-services-under-theIn this issue of the Federal Register, the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary regulations, as published in TD 9827, amends final regulations published under the provisions of the Patient Protection and Affordable Care Act (the Affordable Care Act) and relates to expanded exemptions to protect religious beliefs for entities and individuals with objections based on religious beliefs whose health plans are subject to a mandate of contraceptive coverage through guidance issued pursuant to the Affordable Care Act. These proposed regulations refer to that first set of temporary regulations. The second set of temporary regulations, as published in TD 9828, amends the first set of temporary regulations, as published in TD 9827, to add an exemption to protect moral convictions for entities and individuals with objections based on those beliefs whose health plans are subject to the mandate of contraceptive coverage.
2017-10-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMoral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed RulemakingIn this issue of the Federal Register, the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary regulations, as published in TD 9827, amends...2017-21854"https://www.gpo.gov/fdsys/pkg/FR-2017-10-13/pdf/2017-21854.pdfhttps://www.federalregister.gov/documents/2017/10/13/2017-21854/moral-exemptions-and-accommodations-for-coverage-of-certain-preventive-services-under-the-affordableIn this issue of the Federal Register, the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary regulations, as published in TD 9827, amends final regulations published under the provisions of the Patient Protection and Affordable Care Act (the Affordable Care Act) and relates to expanded exemptions to protect religious beliefs for entities and individuals with objections based on religious beliefs whose health plans are subject to a mandate of contraceptive coverage through guidance issued pursuant to the Affordable Care Act. These proposed regulations refer to the second set of temporary regulations, as published in TD 9828, which amends the first set of temporary regulations, as published in TD 9827, to add an exemption to protect moral convictions for entities and individuals with objections based on those beliefs whose health plans are subject to the mandate of contraceptive coverage.
2017-10-12Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentStreamlining the Section 754 Election StatementThis document contains proposed amendments to the regulation relating to the requirements for making a valid election under section 754 of the Internal Revenue Code of 1986 (Code), as amended. The proposed regulation affects partnerships and their...2017-22080"https://www.gpo.gov/fdsys/pkg/FR-2017-10-12/pdf/2017-22080.pdfhttps://www.federalregister.gov/documents/2017/10/12/2017-22080/streamlining-the-section-754-election-statementThis document contains proposed amendments to the regulation relating to the requirements for making a valid election under section 754 of the Internal Revenue Code of 1986 (Code), as amended. The proposed regulation affects partnerships and their partners by removing a regulatory burden in making an election to adjust the basis of partnership property.
2017-10-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2017-21741"https://www.gpo.gov/fdsys/pkg/FR-2017-10-06/pdf/2017-21741.pdfhttps://www.federalregister.gov/documents/2017/10/06/2017-21741/income-taxes
2017-10-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2017-21742"https://www.gpo.gov/fdsys/pkg/FR-2017-10-06/pdf/2017-21742.pdfhttps://www.federalregister.gov/documents/2017/10/06/2017-21742/income-taxes
2017-10-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMortality Tables for Determining Present Value Under Defined Benefit Pension PlansThis document contains final regulations prescribing mortality tables to be used by most defined benefit pension plans. The tables specify the probability of survival year-by-year for an individual based on age, gender, and other factors. This...2017-21485"https://www.gpo.gov/fdsys/pkg/FR-2017-10-05/pdf/2017-21485.pdfhttps://www.federalregister.gov/documents/2017/10/05/2017-21485/mortality-tables-for-determining-present-value-under-defined-benefit-pension-plansThis document contains final regulations prescribing mortality tables to be used by most defined benefit pension plans. The tables specify the probability of survival year-by-year for an individual based on age, gender, and other factors. This information is used (together with other actuarial assumptions) to calculate the present value of a stream of expected future benefit payments for purposes of determining the minimum funding requirements for a defined benefit plan. These mortality tables are also relevant in determining the minimum required amount of a lump-sum distribution from such a plan. In addition, this document contains final regulations updating the requirements that a plan sponsor must meet to obtain IRS approval to use mortality tables specific to the plan for minimum funding purposes (instead of using the generally applicable mortality tables). These regulations affect participants in, beneficiaries of, employers maintaining, and administrators of certain retirement plans.
2017-09-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPublic Approval of Tax-Exempt Private Activity BondsThis document contains proposed regulations to update and streamline the public approval requirement provided in section 147(f) of the Internal Revenue Code applicable to tax-exempt private activity bonds issued by State and local governments. The...2017-20661"https://www.gpo.gov/fdsys/pkg/FR-2017-09-28/pdf/2017-20661.pdfhttps://www.federalregister.gov/documents/2017/09/28/2017-20661/public-approval-of-tax-exempt-private-activity-bondsThis document contains proposed regulations to update and streamline the public approval requirement provided in section 147(f) of the Internal Revenue Code applicable to tax-exempt private activity bonds issued by State and local governments. The proposed regulations would update the existing regulations on the public approval requirement to reflect statutory changes, to streamline the public approval process, and to reduce burden on State and local governments that issue tax-exempt private activity bonds. This document also withdraws two previous notices of proposed rulemaking on this topic. The proposed regulations affect State and local governments that issue tax-exempt private activity bonds.
2017-09-27RuleDEPARTMENT OF TREASURYTreasury DepartmentWithholding on Payments of Certain Gambling WinningsThis document contains final regulations with respect to the withholding from, and the information reporting on, certain payments of gambling winnings from horse races, dog races, and jai alai and on certain other payments of gambling winnings. The...2017-20720"https://www.gpo.gov/fdsys/pkg/FR-2017-09-27/pdf/2017-20720.pdfhttps://www.federalregister.gov/documents/2017/09/27/2017-20720/withholding-on-payments-of-certain-gambling-winningsThis document contains final regulations with respect to the withholding from, and the information reporting on, certain payments of gambling winnings from horse races, dog races, and jai alai and on certain other payments of gambling winnings. The final regulations affect both payers and payees of the gambling winnings.
2017-09-25Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance on the Definition of Registered FormC1-2017-19753"https://www.gpo.gov/fdsys/pkg/FR-2017-09-25/pdf/C1-2017-19753.pdfhttps://www.federalregister.gov/documents/2017/09/25/C1-2017-19753/guidance-on-the-definition-of-registered-form
2017-09-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUse of Truncated Taxpayer Identification Numbers on Forms W-2, Wage and Tax Statement, Furnished to EmployeesThis document contains proposed amendments to the regulations under sections 6051 and 6052 of the Internal Revenue Code (Code). To aid employers' efforts to protect employees from identity theft, these proposed regulations would amend existing...2017-19910"https://www.gpo.gov/fdsys/pkg/FR-2017-09-20/pdf/2017-19910.pdfhttps://www.federalregister.gov/documents/2017/09/20/2017-19910/use-of-truncated-taxpayer-identification-numbers-on-forms-w-2-wage-and-tax-statement-furnished-toThis document contains proposed amendments to the regulations under sections 6051 and 6052 of the Internal Revenue Code (Code). To aid employers' efforts to protect employees from identity theft, these proposed regulations would amend existing regulations to permit employers to voluntarily truncate employees' social security numbers (SSNs) on copies of Forms W-2, Wage and Tax Statement, that are furnished to employees so that the truncated SSNs appear in the form of IRS truncated taxpayer identification numbers (TTINs). These proposed regulations also would amend the regulations under section 6109 to clarify the application of the truncation rules to Forms W-2 and to add an example illustrating the application of these rules. Additionally, these proposed amendments would delete obsolete provisions and update cross references in the regulations under sections 6051 and 6052. These proposed regulations affect employers who are required to furnish Forms W-2 and employees who receive Forms W-2.
2017-09-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance on the Definition of Registered FormThis document contains proposed regulations that provide guidance on the definitions of registration-required obligation and registered form, including guidance on the issuance of pass-through certificates and participation interests in registered...2017-19753"https://www.gpo.gov/fdsys/pkg/FR-2017-09-19/pdf/2017-19753.pdfhttps://www.federalregister.gov/documents/2017/09/19/2017-19753/guidance-on-the-definition-of-registered-formThis document contains proposed regulations that provide guidance on the definitions of registration-required obligation and registered form, including guidance on the issuance of pass-through certificates and participation interests in registered form. This document also withdraws a portion of previously proposed regulations regarding the definition of a registration-required obligation. The proposed regulations generally are necessary to address changes in market practices as well as issues raised by the statutory repeal of the foreign-targeted bearer obligation exception to the registered form requirement. The proposed regulations will affect issuers and holders of obligations in registered form as well as issuers and holders of registration-required obligations that are not issued in registered form.
2017-09-15Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRevision of Regulations Under Chapter 3 Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons; CorrectionThis document contains a correction to a notice of proposed rulemaking (REG-134247-16) that was published in the Federal Register on Friday, January 6, 2017 (82 FR 1645). The notice of proposed rulemaking under section 1441 of the Internal Revenue Code...2017-19538"https://www.gpo.gov/fdsys/pkg/FR-2017-09-15/pdf/2017-19538.pdfhttps://www.federalregister.gov/documents/2017/09/15/2017-19538/revision-of-regulations-under-chapter-3-regarding-withholding-of-tax-on-certain-us-source-incomeThis document contains a correction to a notice of proposed rulemaking (REG-134247-16) that was published in the Federal Register on Friday, January 6, 2017 (82 FR 1645). The notice of proposed rulemaking under section 1441 of the Internal Revenue Code of 1986 (Code) relates to withholding of tax on certain U.S. source income paid to foreign persons and requirements for certain claims for refund or credit of income tax made by foreign persons.
2017-09-15Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentChapter 4 Regulations Relating to Verification and Certification Requirements for Certain Entities and Reporting by Foreign Financial Institutions; CorrectionThis document contains a correction to a notice of proposed rulemaking (REG-103477-14) that was published in the Federal Register on Friday, January 6, 2017 (82 FR 1629). The notice of proposed rulemaking under chapter 4 of the Subtitle A (sections...2017-19540"https://www.gpo.gov/fdsys/pkg/FR-2017-09-15/pdf/2017-19540.pdfhttps://www.federalregister.gov/documents/2017/09/15/2017-19540/chapter-4-regulations-relating-to-verification-and-certification-requirements-for-certain-entitiesThis document contains a correction to a notice of proposed rulemaking (REG-103477-14) that was published in the Federal Register on Friday, January 6, 2017 (82 FR 1629). The notice of proposed rulemaking under chapter 4 of the Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) relates to verification and certification requirements for certain entities and reporting by foreign financial institutions.
2017-09-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2017-19396"https://www.gpo.gov/fdsys/pkg/FR-2017-09-13/pdf/2017-19396.pdfhttps://www.federalregister.gov/documents/2017/09/13/2017-19396/income-taxes
2017-09-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2017-19397"https://www.gpo.gov/fdsys/pkg/FR-2017-09-13/pdf/2017-19397.pdfhttps://www.federalregister.gov/documents/2017/09/13/2017-19397/income-taxes
2017-09-07RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance for Determining Stock Ownership; CorrectionThis document contains corrections to the final regulations (T.D. 9812) that were published in the Federal Register on Wednesday, January 18, 2017. The regulations identify certain stock of a foreign corporation that is disregarded in calculating...2017-18983"https://www.gpo.gov/fdsys/pkg/FR-2017-09-07/pdf/2017-18983.pdfhttps://www.federalregister.gov/documents/2017/09/07/2017-18983/guidance-for-determining-stock-ownership-correctionThis document contains corrections to the final regulations (T.D. 9812) that were published in the Federal Register on Wednesday, January 18, 2017. The regulations identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation.
2017-09-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTransfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners; CorrectionThis document contains corrections to the temporary regulations (T.D. 9814) that were published in the Federal Register on Thursday, January 19, 2017 (82 FR 7582). The regulations address transfers of appreciated property by United States persons to...2017-18691"https://www.gpo.gov/fdsys/pkg/FR-2017-09-05/pdf/2017-18691.pdfhttps://www.federalregister.gov/documents/2017/09/05/2017-18691/transfers-of-certain-property-by-us-persons-to-partnerships-with-related-foreign-partners-correctionThis document contains corrections to the temporary regulations (T.D. 9814) that were published in the Federal Register on Thursday, January 19, 2017 (82 FR 7582). The regulations address transfers of appreciated property by United States persons to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied.
2017-08-14RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Guidance for Tax-Exempt Bonds; CorrectionThis document contains a correction to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue...2017-17135"https://www.gpo.gov/fdsys/pkg/FR-2017-08-14/pdf/2017-17135.pdfhttps://www.federalregister.gov/documents/2017/08/14/2017-17135/arbitrage-guidance-for-tax-exempt-bonds-correctionThis document contains a correction to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue Code applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments.
2017-07-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentHealth Insurance Premium Tax CreditThis document contains final regulations relating to the health insurance premium tax credit. These regulations affect individuals who enroll in qualified health plans through Affordable Insurance Exchanges (Exchanges, also called Marketplaces) and...2017-15642"https://www.gpo.gov/fdsys/pkg/FR-2017-07-26/pdf/2017-15642.pdfhttps://www.federalregister.gov/documents/2017/07/26/2017-15642/health-insurance-premium-tax-creditThis document contains final regulations relating to the health insurance premium tax credit. These regulations affect individuals who enroll in qualified health plans through Affordable Insurance Exchanges (Exchanges, also called Marketplaces) and claim the premium tax credit and Exchanges that make qualified health plans available to individuals.
2017-07-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentBranded Prescription Drug FeeThis document contains final regulations that define the term controlled group for purposes of the branded prescription drug fee. The final regulations supersede and adopt the text of temporary regulations that define the term controlled group. The...2017-15643"https://www.gpo.gov/fdsys/pkg/FR-2017-07-26/pdf/2017-15643.pdfhttps://www.federalregister.gov/documents/2017/07/26/2017-15643/branded-prescription-drug-feeThis document contains final regulations that define the term controlled group for purposes of the branded prescription drug fee. The final regulations supersede and adopt the text of temporary regulations that define the term controlled group. The final regulations affect persons engaged in the business of manufacturing or importing certain branded prescription drugs.
2017-07-25Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentNuclear Decommissioning Funds; HearingThis document provides a notice of public hearing on proposed changes to the regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power...2017-15543"https://www.gpo.gov/fdsys/pkg/FR-2017-07-25/pdf/2017-15543.pdfhttps://www.federalregister.gov/documents/2017/07/25/2017-15543/nuclear-decommissioning-funds-hearingThis document provides a notice of public hearing on proposed changes to the regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants and the use of the amounts in those trusts to decommission nuclear plants.
2017-07-20RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReturn Due Date and Extended Due Date ChangesThis document contains final and temporary regulations that update the due dates and extensions of time to file certain tax returns and information returns. The dates are updated to reflect the new statutory requirements set by section 2006 of the...2017-15209"https://www.gpo.gov/fdsys/pkg/FR-2017-07-20/pdf/2017-15209.pdfhttps://www.federalregister.gov/documents/2017/07/20/2017-15209/return-due-date-and-extended-due-date-changesThis document contains final and temporary regulations that update the due dates and extensions of time to file certain tax returns and information returns. The dates are updated to reflect the new statutory requirements set by section 2006 of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 and section 201 of the Protecting Americans from Tax Hikes Act of 2015. These regulations affect taxpayers who file Form W-2 (series, except Form W-2G), Form W-3, Form 990 (series), Form 1099-MISC, Form 1041, Form 1041-A, Form 1065, Form 1120 (series), Form 4720, Form 5227, Form 6069, Form 8804, or Form 8870.
2017-07-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReturn Due Date and Extended Due Date ChangesIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that update the due dates and extensions of time to file certain tax returns and information returns. The text of those regulations...2017-15211"https://www.gpo.gov/fdsys/pkg/FR-2017-07-20/pdf/2017-15211.pdfhttps://www.federalregister.gov/documents/2017/07/20/2017-15211/return-due-date-and-extended-due-date-changesIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that update the due dates and extensions of time to file certain tax returns and information returns. The text of those regulations also serves as the text of these proposed regulations.
2017-07-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSpecial Enrollment Examination User Fee for Enrolled AgentsThis document contains a final regulation changing the amount of the user fee for the special enrollment examination to become an enrolled agent. The charging of user fees is authorized by the Independent Offices Appropriations Act of 1952. The final...2017-15210"https://www.gpo.gov/fdsys/pkg/FR-2017-07-19/pdf/2017-15210.pdfhttps://www.federalregister.gov/documents/2017/07/19/2017-15210/special-enrollment-examination-user-fee-for-enrolled-agentsThis document contains a final regulation changing the amount of the user fee for the special enrollment examination to become an enrolled agent. The charging of user fees is authorized by the Independent Offices Appropriations Act of 1952. The final regulation affects individuals taking the enrolled agent special enrollment examination.
2017-07-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTransactions Involving the Transfer of No Net ValueThis document withdraws the remaining part of a notice of proposed rulemaking containing proposed regulations that would have required an exchange or distribution of net value for certain corporate formations and reorganizations to qualify for...2017-14723"https://www.gpo.gov/fdsys/pkg/FR-2017-07-13/pdf/2017-14723.pdfhttps://www.federalregister.gov/documents/2017/07/13/2017-14723/transactions-involving-the-transfer-of-no-net-valueThis document withdraws the remaining part of a notice of proposed rulemaking containing proposed regulations that would have required an exchange or distribution of net value for certain corporate formations and reorganizations to qualify for nonrecognition treatment under the Internal Revenue Code (Code). Other parts of the notice of proposed rulemaking were previously adopted as final regulations. The proposed regulations being withdrawn also addressed the treatment of certain distributions not qualifying for tax-free treatment under section 332 of the Code. The proposed regulations being withdrawn would have affected corporations and their shareholders.
2017-06-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities; CorrectionThis document contains a correction to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of Subtitle A (sections 1471...2017-13631"https://www.gpo.gov/fdsys/pkg/FR-2017-06-30/pdf/2017-13631.pdfhttps://www.federalregister.gov/documents/2017/06/30/2017-13631/regulations-relating-to-information-reporting-by-foreign-financial-institutions-and-withholding-onThis document contains a correction to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) relate to information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities.
2017-06-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities; CorrectionThis document contains corrections to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of the Subtitle A (sections 1471...2017-13632"https://www.gpo.gov/fdsys/pkg/FR-2017-06-30/pdf/2017-13632.pdfhttps://www.federalregister.gov/documents/2017/06/30/2017-13632/regulations-relating-to-information-reporting-by-foreign-financial-institutions-and-withholding-onThis document contains corrections to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of the Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) relate to information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities.
2017-06-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidelines for the Streamlined Process of Applying for Recognition of Section 501(c)(3) StatusThis document contains final regulations that allow the Commissioner of Internal Revenue to adopt a streamlined application process that eligible organizations may use to apply for recognition of tax-exempt status under section 501(c)(3) of the...2017-13866"https://www.gpo.gov/fdsys/pkg/FR-2017-06-30/pdf/2017-13866.pdfhttps://www.federalregister.gov/documents/2017/06/30/2017-13866/guidelines-for-the-streamlined-process-of-applying-for-recognition-of-section-501c3-statusThis document contains final regulations that allow the Commissioner of Internal Revenue to adopt a streamlined application process that eligible organizations may use to apply for recognition of tax-exempt status under section 501(c)(3) of the Internal Revenue Code (Code). The final regulations affect organizations seeking recognition of tax-exempt status under section 501(c)(3).
2017-06-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons, Information Reporting and Backup Withholding on Payments Made to Certain U.S. Persons, and Portfolio Interest Treatment; CorrectionThis document contains corrections to final and temporary regulations (TD 9808), which were published in the Federal Register on Friday, January 6, 2017 (82 FR 2046). These regulations are related to withholding of tax on certain U.S. source income...2017-13634"https://www.gpo.gov/fdsys/pkg/FR-2017-06-30/pdf/2017-13634.pdfhttps://www.federalregister.gov/documents/2017/06/30/2017-13634/regulations-regarding-withholding-of-tax-on-certain-us-source-income-paid-to-foreign-personsThis document contains corrections to final and temporary regulations (TD 9808), which were published in the Federal Register on Friday, January 6, 2017 (82 FR 2046). These regulations are related to withholding of tax on certain U.S. source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. persons, and portfolio interest paid to nonresident alien individuals and foreign corporations.
2017-06-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCentralized Partnership Audit RegimeThis document contains proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership...2017-12308"https://www.gpo.gov/fdsys/pkg/FR-2017-06-14/pdf/2017-12308.pdfhttps://www.federalregister.gov/documents/2017/06/14/2017-12308/centralized-partnership-audit-regimeThis document contains proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules for partnerships subject to the new regime, including procedures for electing out of the centralized partnership audit regime, filing administrative adjustment requests, and the determination of amounts owed by the partnership or its partners attributable to adjustments that arise out of an examination of a partnership. The proposed regulations also address the scope of the centralized partnership audit regime and provide definitions and special rules that govern its application, including the designation of a partnership representative. The proposed regulations affect partnerships for taxable years beginning after December 31, 2017 and any partnerships that elect application of the centralized partnership audit regime pursuant to Sec. 301.9100-22T for taxable years beginning after November 2, 2015 and before January 1, 2018. This document also provides notice of a public hearing on these proposed regulations. This document also withdraws the notice of proposed rulemaking published in the Federal Register on February 13, 2009 (74 FR 7205), regarding the conversion of partnership items related to listed transactions.
2017-01-31RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition; Guidance Under Section 355(f); CorrectionThis document contains corrections to temporary regulations (TD 9805) that published in the Federal Register on Monday, December 19, 2016 (81 FR 91738). The temporary regulations provide guidance regarding the distribution by a distributing corporation...2017-01055"https://www.gpo.gov/fdsys/pkg/FR-2017-01-31/pdf/2017-01055.pdfhttps://www.federalregister.gov/documents/2017/01/31/2017-01055/guidance-under-section-355e-regarding-predecessors-successors-and-limitation-on-gain-recognitionThis document contains corrections to temporary regulations (TD 9805) that published in the Federal Register on Monday, December 19, 2016 (81 FR 91738). The temporary regulations provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss.
2017-01-24RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United StatesThis document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments. This document...2017-01163"https://www.gpo.gov/fdsys/pkg/FR-2017-01-24/pdf/2017-01163.pdfhttps://www.federalregister.gov/documents/2017/01/24/2017-01163/dividend-equivalents-from-sources-within-the-united-statesThis document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments. This document also provides guidance to withholding agents that are responsible for withholding U.S. tax with respect to a dividend equivalent, as well as certain other parties to section 871(m) transactions and their agents.
2017-01-24Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United StatesThis document contains proposed regulations relating to certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.2017-01161"https://www.gpo.gov/fdsys/pkg/FR-2017-01-24/pdf/2017-01161.pdfhttps://www.federalregister.gov/documents/2017/01/24/2017-01161/dividend-equivalents-from-sources-within-the-united-statesThis document contains proposed regulations relating to certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.
2017-01-24RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Interests in Corporations as Stock or Indebtedness; Correction.This document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 (81 FR 72858). The regulations relate to the determination of whether an interest in a...2017-00497"https://www.gpo.gov/fdsys/pkg/FR-2017-01-24/pdf/2017-00497.pdfhttps://www.federalregister.gov/documents/2017/01/24/2017-00497/treatment-of-certain-interests-in-corporations-as-stock-or-indebtedness-correctionThis document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 (81 FR 72858). The regulations relate to the determination of whether an interest in a corporation is treated as stock or indebtedness for all purposes of the Internal Revenue Code.
2017-01-24RuleDEPARTMENT OF THE TREASURYTreasury DepartmentQualifying Income From Activities of Publicly Traded Partnerships With Respect to Minerals or Natural ResourcesThis document contains final regulations under section 7704(d)(1)(E) of the Internal Revenue Code (Code) relating to the qualifying income exception for publicly traded partnerships to not be treated as corporations for Federal income tax purposes....2017-01208"https://www.gpo.gov/fdsys/pkg/FR-2017-01-24/pdf/2017-01208.pdfhttps://www.federalregister.gov/documents/2017/01/24/2017-01208/qualifying-income-from-activities-of-publicly-traded-partnerships-with-respect-to-minerals-orThis document contains final regulations under section 7704(d)(1)(E) of the Internal Revenue Code (Code) relating to the qualifying income exception for publicly traded partnerships to not be treated as corporations for Federal income tax purposes. Specifically, these regulations define the activities that generate qualifying income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or natural resources. These regulations affect publicly traded partnerships and their partners.
2017-01-24RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Interests in Corporations as Stock or Indebtedness; CorrectionThis document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 (81 FR 72858). The regulations relate to the determination of whether an interest in a...2017-00498"https://www.gpo.gov/fdsys/pkg/FR-2017-01-24/pdf/2017-00498.pdfhttps://www.federalregister.gov/documents/2017/01/24/2017-00498/treatment-of-certain-interests-in-corporations-as-stock-or-indebtedness-correctionThis document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 (81 FR 72858). The regulations relate to the determination of whether an interest in a corporation is treated as stock or indebtedness for all purposes of the Internal Revenue Code.
2017-01-23Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce for Certain Statistical Purposes and Related Activities; CorrectionThis document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulation (REG-133353-16) that was published in the Federal Register on Friday, December 9, 2016. The proposed regulations authorize the disclosure...2017-00946"https://www.gpo.gov/fdsys/pkg/FR-2017-01-23/pdf/2017-00946.pdfhttps://www.federalregister.gov/documents/2017/01/23/2017-00946/disclosures-of-return-information-reflected-on-returns-to-officers-and-employees-of-the-departmentThis document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulation (REG-133353-16) that was published in the Federal Register on Friday, December 9, 2016. The proposed regulations authorize the disclosure of specified return information to the Census Bureau (Bureau) for purposes of structuring the censuses and national economic accounts and conducting related statistical activities authorized by title 13.
2017-01-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTransfers of Certain Property by U.S. Persons to Partnerships With Related Foreign PartnersIn the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under sections 197, 704, 721(c), and 6038B of the Internal Revenue Code (Code) that address transfers of appreciated property by U.S....2017-01048"https://www.gpo.gov/fdsys/pkg/FR-2017-01-19/pdf/2017-01048.pdfhttps://www.federalregister.gov/documents/2017/01/19/2017-01048/transfers-of-certain-property-by-us-persons-to-partnerships-with-related-foreign-partnersIn the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under sections 197, 704, 721(c), and 6038B of the Internal Revenue Code (Code) that address transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. The temporary regulations affect U.S. partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of these proposed regulations.
2017-01-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of DependentThis document withdraws proposed regulations relating to the definition of an authorized placement agency for purposes of a dependency exemption for a child placed for adoption that were issued prior to the changes made to the law by the Working...2017-01056"https://www.gpo.gov/fdsys/pkg/FR-2017-01-19/pdf/2017-01056.pdfhttps://www.federalregister.gov/documents/2017/01/19/2017-01056/definition-of-dependentThis document withdraws proposed regulations relating to the definition of an authorized placement agency for purposes of a dependency exemption for a child placed for adoption that were issued prior to the changes made to the law by the Working Families Tax Relief Act of 2004 (WFTRA). This document contains proposed regulations that reflect changes made by WFTRA and by the Fostering Connections to Success and Increasing Adoptions Act of 2008 (FCSIAA) relating to the dependency exemption. This document also contains proposed regulations that, to reflect current law, amend the regulations relating to the surviving spouse and head of household filing statuses, the tax tables for individuals, the child and dependent care credit, the earned income credit, the standard deduction, joint tax returns, and taxpayer identification numbers for children placed for adoption. These proposed regulations change the IRS's position regarding the category of taxpayers permitted to claim the childless earned income credit. In determining a taxpayer's eligibility to claim a dependency exemption, these proposed regulations change the IRS's position regarding the adjusted gross income of a taxpayer filing a joint return for purposes of the tiebreaker rules and the source of support of certain payments that originated as governmental payments. These regulations provide guidance to individuals who may claim certain child-related tax benefits.
2017-01-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentApplication of Modified Carryover Basis to General Basis RulesThis document contains final regulations regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code (Code). Specifically, the final regulations modify provisions of the Treasury Regulations involving...2017-01365"https://www.gpo.gov/fdsys/pkg/FR-2017-01-19/pdf/2017-01365.pdfhttps://www.federalregister.gov/documents/2017/01/19/2017-01365/application-of-modified-carryover-basis-to-general-basis-rulesThis document contains final regulations regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code (Code). Specifically, the final regulations modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.
2017-01-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTransfers of Certain Property by U.S. Persons to Partnerships With Related Foreign PartnersThis document contains temporary regulations that address transfers of appreciated property by United States persons (U.S. persons) to partnerships with foreign partners related to the transferor. The regulations override the rules providing for...2017-01049"https://www.gpo.gov/fdsys/pkg/FR-2017-01-19/pdf/2017-01049.pdfhttps://www.federalregister.gov/documents/2017/01/19/2017-01049/transfers-of-certain-property-by-us-persons-to-partnerships-with-related-foreign-partnersThis document contains temporary regulations that address transfers of appreciated property by United States persons (U.S. persons) to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied. The document also contains regulations under sections 197, 704, and 6038B that apply to certain transfers described in section 721. The regulations affect U.S. partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross-references to coordinate the application of the temporary regulations.
2017-01-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRules Regarding Inversions and Related Transactions; Notice of Proposed Rulemaking by Cross-Reference to Temporary RegulationsIn the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are amending portions of temporary regulations that address certain transactions that are structured to avoid...2017-00637"https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/pdf/2017-00637.pdfhttps://www.federalregister.gov/documents/2017/01/18/2017-00637/rules-regarding-inversions-and-related-transactions-notice-of-proposed-rulemaking-by-cross-referenceIn the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are amending portions of temporary regulations that address certain transactions that are structured to avoid the purposes of section 7874 of the Internal Revenue Code (Code). The temporary regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The text of the temporary regulations in the Rules and Regulations section of this issue of the Federal Register also serves as the text of these proposed regulations.
2017-01-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]This document contains final regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. The final regulations address the length of time during which a RIC or a REIT may be subject to corporate level tax on...2017-00479"https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/pdf/2017-00479.pdfhttps://www.federalregister.gov/documents/2017/01/18/2017-00479/certain-transfers-of-property-to-regulated-investment-companies-rics-and-real-estate-investmentThis document contains final regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. The final regulations address the length of time during which a RIC or a REIT may be subject to corporate level tax on certain dispositions of property. The final regulations affect RICs and REITs.
2017-01-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinitions of Qualified Matching Contributions and Qualified Nonelective ContributionsThis document contains proposed amendments to the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations relating to certain qualified retirement plans that contain cash or deferred...2017-00876"https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/pdf/2017-00876.pdfhttps://www.federalregister.gov/documents/2017/01/18/2017-00876/definitions-of-qualified-matching-contributions-and-qualified-nonelective-contributionsThis document contains proposed amendments to the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations relating to certain qualified retirement plans that contain cash or deferred arrangements under section 401(k) or that provide for matching contributions or employee contributions under section 401(m). Under these regulations, employer contributions to a plan would be able to qualify as QMACs or QNECs if they satisfy applicable nonforfeitability and distribution requirements at the time they are allocated to participants' accounts, but need not meet these requirements when they are contributed to the plan. These regulations would affect participants in, beneficiaries of, employers maintaining, and administrators of tax-qualified plans that contain cash or deferred arrangements or provide for matching contributions or employee contributions.
2017-01-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRules Regarding Inversions and Related Transactions; Partial Withdrawal of Notice of Proposed RulemakingThis document withdraws portions of a notice of proposed rulemaking (REG-135734-14) published on April 8, 2016, in the Federal Register (81 FR 20588). The withdrawn portions relate to exceptions to general rules addressing certain transactions that are...2017-00636"https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/pdf/2017-00636.pdfhttps://www.federalregister.gov/documents/2017/01/18/2017-00636/rules-regarding-inversions-and-related-transactions-partial-withdrawal-of-notice-of-proposedThis document withdraws portions of a notice of proposed rulemaking (REG-135734-14) published on April 8, 2016, in the Federal Register (81 FR 20588). The withdrawn portions relate to exceptions to general rules addressing certain transactions that are structured to avoid the purposes of section 7874 of the Internal Revenue Code (Code).
2017-01-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance for Determining Stock Ownership; Rules Regarding Inversions and Related TransactionsThis document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These...2017-00643"https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/pdf/2017-00643.pdfhttps://www.federalregister.gov/documents/2017/01/18/2017-00643/guidance-for-determining-stock-ownership-rules-regarding-inversions-and-related-transactionsThis document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register.
2017-01-06Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRevision of Regulations Under Chapter 3 Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign PersonsIn the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are issuing temporary regulations (TD 9808) that revise certain provisions of the final regulations regarding...2016-31589"https://www.gpo.gov/fdsys/pkg/FR-2017-01-06/pdf/2016-31589.pdfhttps://www.federalregister.gov/documents/2017/01/06/2016-31589/revision-of-regulations-under-chapter-3-regarding-withholding-of-tax-on-certain-us-source-incomeIn the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are issuing temporary regulations (TD 9808) that revise certain provisions of the final regulations regarding withholding of tax on certain U.S. source income paid to foreign persons and requirements for certain claims for refund or credit of income tax made by foreign persons. The text of the temporary regulations also serves as the text of these proposed regulations.
2017-01-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons, Information Reporting and Backup Withholding on Payments Made to Certain U.S. Persons, and Portfolio Interest TreatmentThis document contains final and temporary regulations regarding withholding of tax on certain U.S. source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. persons, and portfolio...2016-31590"https://www.gpo.gov/fdsys/pkg/FR-2017-01-06/pdf/2016-31590.pdfhttps://www.federalregister.gov/documents/2017/01/06/2016-31590/regulations-regarding-withholding-of-tax-on-certain-us-source-income-paid-to-foreign-personsThis document contains final and temporary regulations regarding withholding of tax on certain U.S. source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. persons, and portfolio interest paid to nonresident alien individuals and foreign corporations. This document finalizes (with minor changes) certain proposed regulations under chapters 3 and 61 and sections 871, 3406, and 6402 of the Internal Revenue Code of 1986 (Code), and withdraws corresponding temporary regulations. This document also includes temporary regulations providing additional rules under chapter 3 of the Code. The text of the temporary regulations also serves as the text of the proposed regulations set forth in a notice of proposed rulemaking published in the Proposed Rules section of this issue of the Federal Register. The temporary regulations affect persons making payments of U.S. source income to foreign persons.
2017-01-06Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentChapter 4 Regulations Relating to Verification and Certification Requirements for Certain Entities and Reporting by Foreign Financial InstitutionsThis document contains proposed regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) describing the verification requirements (including certifications of compliance) and events of default...2016-31599"https://www.gpo.gov/fdsys/pkg/FR-2017-01-06/pdf/2016-31599.pdfhttps://www.federalregister.gov/documents/2017/01/06/2016-31599/chapter-4-regulations-relating-to-verification-and-certification-requirements-for-certain-entitiesThis document contains proposed regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) describing the verification requirements (including certifications of compliance) and events of default for entities that agree to perform the chapter 4 due diligence, withholding, and reporting requirements on behalf of certain foreign financial institutions (FFIs) or the chapter 4 due diligence and reporting obligations on behalf of certain non-financial foreign entities. These proposed regulations also describe the certification requirements and procedures for IRS's review of certain trustees of trustee-documented trusts and the procedures for IRS's review of periodic certifications provided by registered deemed-compliant FFIs. In addition, these proposed regulations describe the procedures for future modifications to the requirements for certifications of compliance for participating FFIs. These proposed regulations also describe the requirements for certifications of compliance for participating FFIs that are members of consolidated compliance groups. In addition, in the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and IRS are issuing temporary regulations that provide additional guidance under chapter 4 (temporary chapter 4 regulations). The text of the temporary chapter 4 regulations also serves as the text of the regulations contained in this document that are proposed by cross-reference to the temporary chapter 4 regulations. The preamble to the temporary chapter 4 regulations explains the temporary chapter 4 regulations and these proposed regulations that cross-reference to the temporary chapter 4 regulations.
2017-01-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign EntitiesThis document contains final and temporary regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) regarding information reporting by foreign financial institutions (FFIs) with respect to U.S....2016-31601"https://www.gpo.gov/fdsys/pkg/FR-2017-01-06/pdf/2016-31601.pdfhttps://www.federalregister.gov/documents/2017/01/06/2016-31601/regulations-relating-to-information-reporting-by-foreign-financial-institutions-and-withholding-onThis document contains final and temporary regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) regarding information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities. This document finalizes (with changes) certain proposed regulations under chapter 4, and withdraws corresponding temporary regulations. This document also includes temporary regulations providing additional rules under chapter 4. The text of the temporary regulations also serves as the text of proposed regulations set forth in a notice of proposed rulemaking published in the Proposed Rules section of this issue of the Federal Register. The regulations included in this document affect persons making certain U.S.-related payments to FFIs and other foreign persons and payments by FFIs to other persons.
2016-12-30RuleDEPARTMENT OF TREASURYTreasury DepartmentInformation Returns; Winnings From Bingo, Keno, and Slot MachinesThis document contains final regulations under section 6041 regarding the filing of information returns to report winnings from bingo, keno, and slot machine play. The rules update the existing requirements regarding the filing, form, and content of...2016-31575"https://www.gpo.gov/fdsys/pkg/FR-2016-12-30/pdf/2016-31575.pdfhttps://www.federalregister.gov/documents/2016/12/30/2016-31575/information-returns-winnings-from-bingo-keno-and-slot-machinesThis document contains final regulations under section 6041 regarding the filing of information returns to report winnings from bingo, keno, and slot machine play. The rules update the existing requirements regarding the filing, form, and content of such information returns; allow for an additional form of payee identification; and provide an optional aggregate reporting method. The final regulations affect persons who pay winnings of $1,200 or more from bingo and slot machine play, $1,500 or more from keno, and recipients of such payments.
2016-12-30Proposed RuleDEPARTMENT OF TREASURYTreasury DepartmentWithholding on Payments of Certain Gambling WinningsThis document contains proposed regulations under section 3402(q) with respect to withholding on certain payments of gambling winnings from horse races, dog races, and jai alai and on certain other payments of gambling winnings. The proposed...2016-31579"https://www.gpo.gov/fdsys/pkg/FR-2016-12-30/pdf/2016-31579.pdfhttps://www.federalregister.gov/documents/2016/12/30/2016-31579/withholding-on-payments-of-certain-gambling-winningsThis document contains proposed regulations under section 3402(q) with respect to withholding on certain payments of gambling winnings from horse races, dog races, and jai alai and on certain other payments of gambling winnings. The proposed regulations affect both payers and payees of the gambling winnings subject to withholding under section 3402(q).
2016-12-29Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentNuclear Decommissioning FundsThis document provides proposed changes to the regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants and the use of the amounts...2016-31205"https://www.gpo.gov/fdsys/pkg/FR-2016-12-29/pdf/2016-31205.pdfhttps://www.federalregister.gov/documents/2016/12/29/2016-31205/nuclear-decommissioning-fundsThis document provides proposed changes to the regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants and the use of the amounts in those trusts to decommission nuclear plants. The proposed regulations revise certain provisions to: Address issues that have arisen as more nuclear plants have begun the decommissioning process; and clarify provisions in the current regulations regarding self-dealing and the definition of substantial completion of decommissioning.
2016-12-29Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMortality Tables for Determining Present Value Under Defined Benefit Pension PlansThis document contains proposed regulations prescribing mortality tables to be used by most defined benefit pension plans. The tables specify the probability of survival year-by-year for an individual based on age, gender, and other factors. This...2016-30906"https://www.gpo.gov/fdsys/pkg/FR-2016-12-29/pdf/2016-30906.pdfhttps://www.federalregister.gov/documents/2016/12/29/2016-30906/mortality-tables-for-determining-present-value-under-defined-benefit-pension-plansThis document contains proposed regulations prescribing mortality tables to be used by most defined benefit pension plans. The tables specify the probability of survival year-by-year for an individual based on age, gender, and other factors. This information is used (together with other actuarial assumptions) to calculate the present value of a stream of expected future benefit payments for purposes of determining the minimum funding requirements for the plan. These mortality tables are also relevant to determining the minimum required amount of a lump-sum distribution from such a plan. In addition, this document contains proposed regulations to update the requirements that a plan sponsor must meet in order to obtain IRS approval to use mortality tables specific to the plan for minimum funding purposes (instead of the generally applicable mortality tables). These regulations affect participants in, beneficiaries of, employers maintaining, and administrators of certain retirement plans.
2016-12-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinitions and Reporting Requirements for Shareholders of Passive Foreign Investment CompaniesThis document contains final regulations that provide guidance on determining ownership of a passive foreign investment company (PFIC) and on certain annual reporting requirements for shareholders of PFICs to file Form 8621, ``Information Return by a...2016-30712"https://www.gpo.gov/fdsys/pkg/FR-2016-12-28/pdf/2016-30712.pdfhttps://www.federalregister.gov/documents/2016/12/28/2016-30712/definitions-and-reporting-requirements-for-shareholders-of-passive-foreign-investment-companiesThis document contains final regulations that provide guidance on determining ownership of a passive foreign investment company (PFIC) and on certain annual reporting requirements for shareholders of PFICs to file Form 8621, ``Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund.'' In addition, the final regulations provide guidance on an exception to the requirement for certain shareholders of foreign corporations to file Form 5471, ``Information Return of U.S. Persons with Respect to Certain Foreign Corporations.'' The regulations finalize proposed regulations and withdraw temporary regulations published on December 31, 2013. The final regulations affect United States persons that own interests in PFICs, and certain United States shareholders of foreign corporations.
2016-12-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations Through Partnerships With Special Allocations; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-114734-16) that was published in the Federal Register on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations provide rules regarding the determination of the...2016-31358"https://www.gpo.gov/fdsys/pkg/FR-2016-12-28/pdf/2016-31358.pdfhttps://www.federalregister.gov/documents/2016/12/28/2016-31358/united-states-property-held-by-controlled-foreign-corporations-through-partnerships-with-specialThis document contains corrections to a notice of proposed rulemaking (REG-114734-16) that was published in the Federal Register on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations provide rules regarding the determination of the amount of the United States property treated as held by a controlled foreign corporation (CFC) through a partnership.
2016-12-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; CorrectionThis document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of...2016-31364"https://www.gpo.gov/fdsys/pkg/FR-2016-12-28/pdf/2016-31364.pdfhttps://www.federalregister.gov/documents/2016/12/28/2016-31364/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships.
2016-12-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; CorrectionThis document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of...2016-31411"https://www.gpo.gov/fdsys/pkg/FR-2016-12-28/pdf/2016-31411.pdfhttps://www.federalregister.gov/documents/2016/12/28/2016-31411/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships.
2016-12-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPremium Tax Credit Regulation VIThis document contains final regulations relating to the health insurance premium tax credit (premium tax credit). These final regulations affect individuals who enroll in qualified health plans through Health Insurance Exchanges (Exchanges, also...2016-30037"https://www.gpo.gov/fdsys/pkg/FR-2016-12-19/pdf/2016-30037.pdfhttps://www.federalregister.gov/documents/2016/12/19/2016-30037/premium-tax-credit-regulation-viThis document contains final regulations relating to the health insurance premium tax credit (premium tax credit). These final regulations affect individuals who enroll in qualified health plans through Health Insurance Exchanges (Exchanges, also called Marketplaces) and claim the premium tax credit, and Exchanges that make qualified health plans available to individuals and employers. These final regulations also affect individuals who are eligible for employer-sponsored health coverage.
2016-12-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition; Guidance Under Section 355(f)This document contains temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations...2016-30160"https://www.gpo.gov/fdsys/pkg/FR-2016-12-19/pdf/2016-30160.pdfhttps://www.federalregister.gov/documents/2016/12/19/2016-30160/guidance-under-section-355e-regarding-predecessors-successors-and-limitation-on-gain-recognitionThis document contains temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code (Code) to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) of the Code causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. These temporary regulations affect corporations that distribute the stock or securities of controlled corporations and the shareholders or security holders of those distributing corporations. The text of these temporary regulations also serves as the text of the proposed regulations in the related notice of proposed rulemaking (REG-140328-15) set forth in the Proposed Rules section in this issue of the Federal Register.
2016-12-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Regarding Predecessors and Successors Under Section 355(e); Limitation on Gain Recognition; Guidance Under Section 355(f)In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation...2016-30156"https://www.gpo.gov/fdsys/pkg/FR-2016-12-19/pdf/2016-30156.pdfhttps://www.federalregister.gov/documents/2016/12/19/2016-30156/guidance-regarding-predecessors-and-successors-under-section-355e-limitation-on-gain-recognitionIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. Those temporary regulations affect corporations that distribute the stock or securities of controlled corporations and their shareholders or security holders of those distributing corporations. The text of those temporary regulations serves as the text of these proposed regulations.
2016-12-16RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property to Foreign CorporationsThis document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going...2016-29791"https://www.gpo.gov/fdsys/pkg/FR-2016-12-16/pdf/2016-29791.pdfhttps://www.federalregister.gov/documents/2016/12/16/2016-29791/treatment-of-certain-transfers-of-property-to-foreign-corporationsThis document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The regulations also combine certain sections of the existing regulations under section 367(a) into a single section. This document also withdraws certain temporary regulations.
2016-12-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038AThis document contains final regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance...2016-29641"https://www.gpo.gov/fdsys/pkg/FR-2016-12-13/pdf/2016-29641.pdfhttps://www.federalregister.gov/documents/2016/12/13/2016-29641/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-forThis document contains final regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Internal Revenue Code.
2016-12-09RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIssue Price Definition for Tax-Exempt BondsThis document contains final regulations on the definition of issue price for purposes of the arbitrage investment restrictions that apply to tax-exempt bonds and other tax-advantaged bonds. These final regulations affect State and local governments...2016-29486"https://www.gpo.gov/fdsys/pkg/FR-2016-12-09/pdf/2016-29486.pdfhttps://www.federalregister.gov/documents/2016/12/09/2016-29486/issue-price-definition-for-tax-exempt-bondsThis document contains final regulations on the definition of issue price for purposes of the arbitrage investment restrictions that apply to tax-exempt bonds and other tax-advantaged bonds. These final regulations affect State and local governments that issue tax-exempt bonds and other tax-advantaged bonds.
2016-12-09Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce for Certain Statistical Purposes and Related ActivitiesIn the Rules and Regulations section of this issue of the Federal Register the IRS is issuing temporary regulations authorizing the disclosure of specified return information to the Bureau of the Census (Bureau) for purposes of structuring the censuses...2016-29490"https://www.gpo.gov/fdsys/pkg/FR-2016-12-09/pdf/2016-29490.pdfhttps://www.federalregister.gov/documents/2016/12/09/2016-29490/disclosures-of-return-information-reflected-on-returns-to-officers-and-employees-of-the-departmentIn the Rules and Regulations section of this issue of the Federal Register the IRS is issuing temporary regulations authorizing the disclosure of specified return information to the Bureau of the Census (Bureau) for purposes of structuring the censuses and national economic accounts and conducting related statistical activities authorized by title 13. The temporary regulations are made pursuant to a request from the Secretary of Commerce. The temporary regulations also provide clarifying language for an item of return information and remove duplicative paragraphs contained in the existing final regulations. These regulations require no action by taxpayers and have no effect on their tax liabilities. Thus, no taxpayers are likely to be affected by the disclosures authorized by this guidance. The text of the temporary regulations published in the Rules and Regulations section of the Federal Register serves as the text of these proposed regulations.
2016-12-09Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentHealth Insurance Providers FeeThis document contains proposed regulations that would modify the current definition of ``net premiums written'' for purposes of the fee imposed by section 9010 of the Patient Protection and Affordable Care Act, as amended. The proposed regulations...2016-29487"https://www.gpo.gov/fdsys/pkg/FR-2016-12-09/pdf/2016-29487.pdfhttps://www.federalregister.gov/documents/2016/12/09/2016-29487/health-insurance-providers-feeThis document contains proposed regulations that would modify the current definition of ``net premiums written'' for purposes of the fee imposed by section 9010 of the Patient Protection and Affordable Care Act, as amended. The proposed regulations will affect persons engaged in the business of providing health insurance for United States health risks.
2016-12-09Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElectronic Filing of the Report of Health Insurance Provider InformationThis document proposes to amend the Health Insurance Providers Fee regulations to require certain covered entities engaged in the business of providing health insurance for United States health risks to electronically file Form 8963, ``Report of Health...2016-29489"https://www.gpo.gov/fdsys/pkg/FR-2016-12-09/pdf/2016-29489.pdfhttps://www.federalregister.gov/documents/2016/12/09/2016-29489/electronic-filing-of-the-report-of-health-insurance-provider-informationThis document proposes to amend the Health Insurance Providers Fee regulations to require certain covered entities engaged in the business of providing health insurance for United States health risks to electronically file Form 8963, ``Report of Health Insurance Provider Information.'' These proposed regulations affect those entities.
2016-12-09RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce for Certain Statistical Purposes and Related ActivitiesThis document contains temporary regulations that authorize the disclosure of certain items of return information to the Bureau of the Census (Bureau) in conformance with section 6103(j)(1) of the Internal Revenue Code (Code). These temporary...2016-29488"https://www.gpo.gov/fdsys/pkg/FR-2016-12-09/pdf/2016-29488.pdfhttps://www.federalregister.gov/documents/2016/12/09/2016-29488/disclosures-of-return-information-reflected-on-returns-to-officers-and-employees-of-the-departmentThis document contains temporary regulations that authorize the disclosure of certain items of return information to the Bureau of the Census (Bureau) in conformance with section 6103(j)(1) of the Internal Revenue Code (Code). These temporary regulations are made pursuant to a request from the Secretary of Commerce. These temporary regulations also provide clarifying language for an item of return information and remove duplicative paragraphs contained in the existing regulations. These temporary regulations require no action by taxpayers and have no effect on their tax liabilities. Thus, no taxpayers are likely to be affected by the disclosures authorized by this guidance. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register.
2016-12-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRecognition and Deferral of Section 987 Gain or LossPublished elsewhere in this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations under section 987 of the Code relating to the recognition and deferral of foreign currency gain or loss under section 987...2016-28377"https://www.gpo.gov/fdsys/pkg/FR-2016-12-08/pdf/2016-28377.pdfhttps://www.federalregister.gov/documents/2016/12/08/2016-28377/recognition-and-deferral-of-section-987-gain-or-lossPublished elsewhere in this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations under section 987 of the Code relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit (QBU) in connection with certain QBU terminations and certain other transactions involving partnerships. The temporary regulations also contain rules providing: An annual deemed termination election for a section 987 QBU; an elective method, available to taxpayers that make the annual deemed termination election, for translating all items of income or loss with respect to a section 987 QBU at the yearly average exchange rate; rules regarding the treatment of section 988 transactions of a section 987 QBU; rules regarding QBUs with the U.S. dollar as their functional currency; rules regarding combinations and separations of section 987 QBUs; rules regarding the translation of income used to pay creditable foreign income taxes; and rules regarding the allocation of assets and liabilities of certain partnerships for purposes of section 987. Finally, the temporary regulations contain rules under section 988 requiring the deferral of certain section 988 loss that arises with respect to related-party loans. The text of the temporary regulations serves as the text of these proposed regulations.
2016-12-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome and Currency Gain or Loss With Respect to a Section 987 QBUThis document contains final regulations that provide guidance under section 987 of the Internal Revenue Code (Code) regarding the determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to...2016-28381"https://www.gpo.gov/fdsys/pkg/FR-2016-12-08/pdf/2016-28381.pdfhttps://www.federalregister.gov/documents/2016/12/08/2016-28381/income-and-currency-gain-or-loss-with-respect-to-a-section-987-qbuThis document contains final regulations that provide guidance under section 987 of the Internal Revenue Code (Code) regarding the determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to section 987, as well as the timing, amount, character, and source of any section 987 gain or loss. Taxpayers affected by these regulations are corporations and individuals that own QBUs subject to section 987. In addition, published elsewhere in this issue of the Federal Register, temporary and proposed regulations (the temporary regulations) are being issued under section 987 to address aspects of the application of section 987 not addressed in these final regulations.
2016-12-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRecognition and Deferral of Section 987 Gain or LossThis document contains temporary regulations under section 987 of the Internal Revenue Code (Code) relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit (QBU) in connection...2016-28380"https://www.gpo.gov/fdsys/pkg/FR-2016-12-08/pdf/2016-28380.pdfhttps://www.federalregister.gov/documents/2016/12/08/2016-28380/recognition-and-deferral-of-section-987-gain-or-lossThis document contains temporary regulations under section 987 of the Internal Revenue Code (Code) relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit (QBU) in connection with certain QBU terminations and certain other transactions involving partnerships. This document also contains temporary regulations under section 987 providing: an annual deemed termination election for a section 987 QBU; an elective method, available to taxpayers that make the annual deemed termination election, for translating all items of income or loss with respect to a section 987 QBU at the yearly average exchange rate; rules regarding the treatment of section 988 transactions of a section 987 QBU; rules regarding QBUs with the U.S. dollar as their functional currency; rules regarding combinations and separations of section 987 QBUs; rules regarding the translation of income used to pay creditable foreign income taxes; and rules regarding the allocation of assets and liabilities of certain partnerships for purposes of section 987. Finally, this document contains temporary regulations under section 988 requiring the deferral of certain section 988 loss that arises with respect to related-party loans. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register. In addition, in the Rules and Regulations section of this issue of the Federal Register, final regulations are being issued under section 987 to provide general guidance under section 987 regarding the determination of the taxable income or loss of a taxpayer with respect to a QBU.
2016-12-07Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCovered Asset AcquisitionsThis document contains proposed Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S. income tax purposes and either are treated as stock...2016-28759"https://www.gpo.gov/fdsys/pkg/FR-2016-12-07/pdf/2016-28759.pdfhttps://www.federalregister.gov/documents/2016/12/07/2016-28759/covered-asset-acquisitionsThis document contains proposed Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S. income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. In the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under section 901(m) (the temporary regulations), the text of which serves as the text of a portion of these proposed regulations. These regulations are necessary to provide guidance on applying section 901(m). These regulations affect taxpayers claiming foreign tax credits.
2016-12-07RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCovered Asset AcquisitionsThis document contains temporary Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S. income tax purposes and either are treated as stock...2016-28755"https://www.gpo.gov/fdsys/pkg/FR-2016-12-07/pdf/2016-28755.pdfhttps://www.federalregister.gov/documents/2016/12/07/2016-28755/covered-asset-acquisitionsThis document contains temporary Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S. income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. These regulations are necessary to provide guidance on applying section 901(m). The text of the temporary regulations also serves in part as the text of the proposed regulations under section 901(m) (REG-129128-14) published in the Proposed Rules section of this issue of the Federal Register.
2016-12-05Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTax Return Preparer Due Diligence Penalty Under Section 6695(g)In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that will modify the existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to...2016-28995"https://www.gpo.gov/fdsys/pkg/FR-2016-12-05/pdf/2016-28995.pdfhttps://www.federalregister.gov/documents/2016/12/05/2016-28995/tax-return-preparer-due-diligence-penalty-under-section-6695gIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that will modify the existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to tax return preparer due diligence. The temporary regulations implement recent law changes that expand the tax return preparer due diligence penalty under section 6695(g) so that it applies to the child tax credit (CTC), additional child tax credit (ACTC), and the American Opportunity Tax Credit (AOTC), in addition to the earned income credit (EIC). The text of those regulations also serves as the text of these proposed regulations.
2016-12-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTax Return Preparer Due Diligence Penalty Under Section 6695(g)This document contains temporary regulations that modify existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to tax return preparer due diligence. These temporary regulations implement recent...2016-28993"https://www.gpo.gov/fdsys/pkg/FR-2016-12-05/pdf/2016-28993.pdfhttps://www.federalregister.gov/documents/2016/12/05/2016-28993/tax-return-preparer-due-diligence-penalty-under-section-6695gThis document contains temporary regulations that modify existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to tax return preparer due diligence. These temporary regulations implement recent law changes that expand the tax return preparer due diligence penalty under section 6695(g) so that it applies to the child tax credit (CTC), additional child tax credit (ACTC), and the American Opportunity Tax Credit (AOTC), in addition to the earned income credit (EIC). The temporary regulations affect tax return preparers. The substance of the temporary regulations is included in the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.
2016-12-02RuleDEPARTMENT OF THE TREASURYTreasury DepartmentConsistent Basis Reporting Between Estate and Person Acquiring Property From DecedentThis document contains final regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (2) regarding the value of property included in a decedent's gross...2016-28906"https://www.gpo.gov/fdsys/pkg/FR-2016-12-02/pdf/2016-28906.pdfhttps://www.federalregister.gov/documents/2016/12/02/2016-28906/consistent-basis-reporting-between-estate-and-person-acquiring-property-from-decedentThis document contains final regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (2) regarding the value of property included in a decedent's gross estate for federal estate tax purposes before June 30, 2016, need not have done so until June 30, 2016. These final regulations are applicable to executors and other persons who file federal estate tax returns required by section 6018(a) or (b) after July 31, 2015.
2016-12-02RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUser Fees for Installment AgreementsThis document contains final regulations that provide user fees for installment agreements. The final regulations affect taxpayers who wish to pay their liabilities through installment agreements.2016-28936"https://www.gpo.gov/fdsys/pkg/FR-2016-12-02/pdf/2016-28936.pdfhttps://www.federalregister.gov/documents/2016/12/02/2016-28936/user-fees-for-installment-agreementsThis document contains final regulations that provide user fees for installment agreements. The final regulations affect taxpayers who wish to pay their liabilities through installment agreements.
2016-11-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDollar-Value LIFO Regulations: Inventory Price Index Computation (IPIC) Method PoolsThis document contains proposed regulations that relate to the establishment of dollar-value last-in, first-out (LIFO) inventory pools by certain taxpayers that use the inventory price index computation (IPIC) pooling method. The proposed regulations...2016-28375"https://www.gpo.gov/fdsys/pkg/FR-2016-11-28/pdf/2016-28375.pdfhttps://www.federalregister.gov/documents/2016/11/28/2016-28375/dollar-value-lifo-regulations-inventory-price-index-computation-ipic-method-poolsThis document contains proposed regulations that relate to the establishment of dollar-value last-in, first-out (LIFO) inventory pools by certain taxpayers that use the inventory price index computation (IPIC) pooling method. The proposed regulations provide rules regarding the proper pooling of manufactured or processed goods and wholesale or retail (resale) goods. The proposed regulations would affect taxpayers who use the IPIC pooling method and whose inventory for a trade or business consists of manufactured or processed goods and resale goods.
2016-11-25Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUpdate to Minimum Present Value Requirements for Defined Benefit Plan DistributionsThis document contains proposed regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These proposed regulations would provide guidance on changes made by the Pension...2016-27907"https://www.gpo.gov/fdsys/pkg/FR-2016-11-25/pdf/2016-27907.pdfhttps://www.federalregister.gov/documents/2016/11/25/2016-27907/update-to-minimum-present-value-requirements-for-defined-benefit-plan-distributionsThis document contains proposed regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These proposed regulations would provide guidance on changes made by the Pension Protection Act of 2006 and would provide other modifications to these rules as well. These regulations would affect participants, beneficiaries, sponsors, and administrators of defined benefit pension plans. This document also provides a notice of a public hearing on these proposed regulations.
2016-11-23Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentFractions RuleThis document contains proposed regulations relating to the application of section 514(c)(9)(E) of the Internal Revenue Code (Code) to partnerships that hold debt-financed real property and have one or more (but not all) qualified tax-exempt...2016-27105"https://www.gpo.gov/fdsys/pkg/FR-2016-11-23/pdf/2016-27105.pdfhttps://www.federalregister.gov/documents/2016/11/23/2016-27105/fractions-ruleThis document contains proposed regulations relating to the application of section 514(c)(9)(E) of the Internal Revenue Code (Code) to partnerships that hold debt-financed real property and have one or more (but not all) qualified tax-exempt organization partners within the meaning of section 514(c)(9)(C). The proposed regulations amend the current regulations under section 514(c)(9)(E) to allow certain allocations resulting from specified common business practices to comply with the rules under section 514(c)(9)(E). These regulations affect partnerships with qualified tax-exempt organization partners and their partners.
2016-11-17RuleDEPARTMENT OF THE TREASURYTreasury DepartmentLiabilities Recognized as Recourse Partnership Liabilities Under Section 752; CorrectionThis document contains corrections to final and temporary regulations (TD 9788) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69282). The final and temporary regulations provide rules concerning how liabilities are...2016-27516"https://www.gpo.gov/fdsys/pkg/FR-2016-11-17/pdf/2016-27516.pdfhttps://www.federalregister.gov/documents/2016/11/17/2016-27516/liabilities-recognized-as-recourse-partnership-liabilities-under-section-752-correctionThis document contains corrections to final and temporary regulations (TD 9788) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69282). The final and temporary regulations provide rules concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code and when certain obligations are recognized for purposes of determining whether a liability is a recourse partnership liability under section 752.
2016-11-17RuleDEPARTMENT OF THE TREASURYTreasury DepartmentLiabilities Recognized as Recourse Partnership Liabilities Under Section 752; CorrectionThis document contains corrections to final and temporary regulations (TD 9788) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69282). The final and temporary regulations provide rules concerning how liabilities are...2016-27517"https://www.gpo.gov/fdsys/pkg/FR-2016-11-17/pdf/2016-27517.pdfhttps://www.federalregister.gov/documents/2016/11/17/2016-27517/liabilities-recognized-as-recourse-partnership-liabilities-under-section-752-correctionThis document contains corrections to final and temporary regulations (TD 9788) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69282). The final and temporary regulations provide rules concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code and when certain obligations are recognized for purposes of determining whether a liability is a recourse partnership liability under section 752.
2016-11-16RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSection 707 Regarding Disguised Sales, Generally; CorrectionThis document contains corrections to final regulations (TD 9787) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69291). The final regulations are under sections 707 and 752 of the Internal Revenue Code.2016-27515"https://www.gpo.gov/fdsys/pkg/FR-2016-11-16/pdf/2016-27515.pdfhttps://www.federalregister.gov/documents/2016/11/16/2016-27515/section-707-regarding-disguised-sales-generally-correctionThis document contains corrections to final regulations (TD 9787) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69291). The final regulations are under sections 707 and 752 of the Internal Revenue Code.
2016-11-10RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRemoval of the 36-Month Non-Payment Testing Period RuleThis document contains final regulations that remove the rule that a deemed discharge of indebtedness for which a Form 1099-C, ``Cancellation of Debt,'' must be filed occurs at the expiration of a 36-month non-payment testing period. The Treasury...2016-27160"https://www.gpo.gov/fdsys/pkg/FR-2016-11-10/pdf/2016-27160.pdfhttps://www.federalregister.gov/documents/2016/11/10/2016-27160/removal-of-the-36-month-non-payment-testing-period-ruleThis document contains final regulations that remove the rule that a deemed discharge of indebtedness for which a Form 1099-C, ``Cancellation of Debt,'' must be filed occurs at the expiration of a 36-month non-payment testing period. The Treasury Department and the IRS are concerned that the rule creates confusion for taxpayers and does not increase tax compliance by debtors or provide the IRS with valuable third-party information that may be used to ensure taxpayer compliance. The final regulations affect certain financial institutions and governmental entities.
2016-11-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCredit for Increasing Research Activities; CorrectionThis document contains corrections to final regulations (TD 9786) that were published in the Federal Register on Tuesday, October 4, 2016 (81 FR 68299). The final regulations provided guidance regarding the application of the credit for increasing...2016-26522"https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26522.pdfhttps://www.federalregister.gov/documents/2016/11/03/2016-26522/credit-for-increasing-research-activities-correctionThis document contains corrections to final regulations (TD 9786) that were published in the Federal Register on Tuesday, October 4, 2016 (81 FR 68299). The final regulations provided guidance regarding the application of the credit for increasing research activities.
2016-11-03Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Related Person Factoring Income; Certain Investments in United States Property; and Stock Redemptions Through Related CorporationsThis document withdraws portions of a notice of proposed rulemaking (INTL-49-86, subsequently converted to REG-209001-86) published in the Federal Register (53 FR 22186) on June 14, 1988, (the 1988 NPRM). The withdrawn portions relate to stock...2016-26423"https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26423.pdfhttps://www.federalregister.gov/documents/2016/11/03/2016-26423/treatment-of-related-person-factoring-income-certain-investments-in-united-states-property-and-stockThis document withdraws portions of a notice of proposed rulemaking (INTL-49-86, subsequently converted to REG-209001-86) published in the Federal Register (53 FR 22186) on June 14, 1988, (the 1988 NPRM). The withdrawn portions relate to stock redemptions through related corporations, the application of section 956 to United States property indirectly held by a controlled foreign corporation (CFC), and certain related party factoring transactions, as well as the definition of the term ``obligation'' for purposes of section 956.
2016-11-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or BusinessThis document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the...2016-26425"https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26425.pdfhttps://www.federalregister.gov/documents/2016/11/03/2016-26425/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income (FPHCI), as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions. This document finalizes proposed regulations, and withdraws temporary regulations, published on September 2, 2015. It also finalizes proposed regulations, and withdraws temporary regulations, published on June 14, 1988. The final regulations affect United States shareholders of CFCs.
2016-11-03Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations Through Partnerships With Special AllocationsThis document contains proposed regulations that provide rules regarding the determination of the amount of United States property treated as held by a controlled foreign corporation (CFC) through a partnership. The proposed regulations affect United...2016-26424"https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26424.pdfhttps://www.federalregister.gov/documents/2016/11/03/2016-26424/united-states-property-held-by-controlled-foreign-corporations-through-partnerships-with-specialThis document contains proposed regulations that provide rules regarding the determination of the amount of United States property treated as held by a controlled foreign corporation (CFC) through a partnership. The proposed regulations affect United States shareholders of CFCs.
2016-10-31RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExcepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration InsuranceThis document contains final regulations regarding the definition of short-term, limited-duration insurance for purposes of the exclusion from the definition of individual health insurance coverage, and standards for travel insurance and supplemental...2016-26162"https://www.gpo.gov/fdsys/pkg/FR-2016-10-31/pdf/2016-26162.pdfhttps://www.federalregister.gov/documents/2016/10/31/2016-26162/excepted-benefits-lifetime-and-annual-limits-and-short-term-limited-duration-insuranceThis document contains final regulations regarding the definition of short-term, limited-duration insurance for purposes of the exclusion from the definition of individual health insurance coverage, and standards for travel insurance and supplemental health insurance coverage to be considered excepted benefits. This document also amends a reference in the final regulations relating to the prohibition on lifetime and annual dollar limits.
2016-10-25Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSpecial Enrollment Examination User Fee for Enrolled AgentsThis document withdraws a proposed regulation relating to the user fee for the special enrollment examination to become an enrolled agent. This document also proposes a new regulation to increase the user fee for the examination to recover the cost to...2016-25776"https://www.gpo.gov/fdsys/pkg/FR-2016-10-25/pdf/2016-25776.pdfhttps://www.federalregister.gov/documents/2016/10/25/2016-25776/special-enrollment-examination-user-fee-for-enrolled-agentsThis document withdraws a proposed regulation relating to the user fee for the special enrollment examination to become an enrolled agent. This document also proposes a new regulation to increase the user fee for the examination to recover the cost to the IRS of overseeing the administration of the examination. The withdrawal and proposal affect individuals taking the enrolled agent special enrollment examination. This document also contains a notice of public hearing on the new proposed regulation.
2016-10-21Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Interests in Corporations as Stock or IndebtednessThe Department of the Treasury (Treasury Department) and the IRS are issuing temporary regulations that affect corporations and partnerships that issue purported indebtedness to related corporations or partnerships in the Rules and Regulations section...2016-25104"https://www.gpo.gov/fdsys/pkg/FR-2016-10-21/pdf/2016-25104.pdfhttps://www.federalregister.gov/documents/2016/10/21/2016-25104/treatment-of-certain-interests-in-corporations-as-stock-or-indebtednessThe Department of the Treasury (Treasury Department) and the IRS are issuing temporary regulations that affect corporations and partnerships that issue purported indebtedness to related corporations or partnerships in the Rules and Regulations section of this issue of the Federal Register. The temporary regulations provide rules addressing the treatment of instruments issued by partnerships, consolidated groups, and certain transactions involving qualified cash- management arrangements. The text of the temporary regulations also serves as the text of these proposed regulations.
2016-10-21RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Interests in Corporations as Stock or IndebtednessThis document contains final and temporary regulations under section 385 of the Internal Revenue Code (Code) that establish threshold documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a...2016-25105"https://www.gpo.gov/fdsys/pkg/FR-2016-10-21/pdf/2016-25105.pdfhttps://www.federalregister.gov/documents/2016/10/21/2016-25105/treatment-of-certain-interests-in-corporations-as-stock-or-indebtednessThis document contains final and temporary regulations under section 385 of the Internal Revenue Code (Code) that establish threshold documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes, and treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes. The final and temporary regulations generally affect corporations, including those that are partners of certain partnerships, when those corporations or partnerships issue purported indebtedness to related corporations or partnerships.
2016-10-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExcise Tax; Tractors, Trailers, Trucks, and Tires; Definition of Highway Vehicle; HearingThis document provides a notice of public hearing on proposed regulations relating to the excise taxes imposed on the sale of highway tractors, trailers, trucks, and tires; the use of heavy vehicles on the highway; and the definition of highway vehicle...2016-25376"https://www.gpo.gov/fdsys/pkg/FR-2016-10-20/pdf/2016-25376.pdfhttps://www.federalregister.gov/documents/2016/10/20/2016-25376/excise-tax-tractors-trailers-trucks-and-tires-definition-of-highway-vehicle-hearingThis document provides a notice of public hearing on proposed regulations relating to the excise taxes imposed on the sale of highway tractors, trailers, trucks, and tires; the use of heavy vehicles on the highway; and the definition of highway vehicle related to these and other taxes.
2016-10-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUser Fees for Installment Agreements; Hearing CancellationThis document provides notice of the cancellation of a public hearing on proposed regulation relating to proposed amendments to the regulations that provide user fees for installment agreements.2016-25055"https://www.gpo.gov/fdsys/pkg/FR-2016-10-17/pdf/2016-25055.pdfhttps://www.federalregister.gov/documents/2016/10/17/2016-25055/user-fees-for-installment-agreements-hearing-cancellationThis document provides notice of the cancellation of a public hearing on proposed regulation relating to proposed amendments to the regulations that provide user fees for installment agreements.
2016-10-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]; HearingThis document provides a notice of a public hearing on proposed IRS regulations that are affecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986.2016-24901"https://www.gpo.gov/fdsys/pkg/FR-2016-10-14/pdf/2016-24901.pdfhttps://www.federalregister.gov/documents/2016/10/14/2016-24901/certain-transfers-of-property-to-regulated-investment-companies-rics-and-real-estate-investmentThis document provides a notice of a public hearing on proposed IRS regulations that are affecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986.
2016-10-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElection To Take Disaster Loss Deduction for Preceding YearIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 165(i) of the Internal Revenue Code (Code) relating to the election to take a disaster loss in the preceding year. The...2016-24674"https://www.gpo.gov/fdsys/pkg/FR-2016-10-14/pdf/2016-24674.pdfhttps://www.federalregister.gov/documents/2016/10/14/2016-24674/election-to-take-disaster-loss-deduction-for-preceding-yearIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 165(i) of the Internal Revenue Code (Code) relating to the election to take a disaster loss in the preceding year. The text of those temporary regulations also serves as the text of these proposed regulations. This document also invites comments from the public regarding these proposed regulations.
2016-10-14RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElection To Take Disaster Loss Deduction for Preceding YearThis document contains final and temporary regulations relating to the election to accelerate the timing of a loss sustained by a taxpayer attributable to a federally declared disaster. The text of the temporary regulations also serves as the text of...2016-24664"https://www.gpo.gov/fdsys/pkg/FR-2016-10-14/pdf/2016-24664.pdfhttps://www.federalregister.gov/documents/2016/10/14/2016-24664/election-to-take-disaster-loss-deduction-for-preceding-yearThis document contains final and temporary regulations relating to the election to accelerate the timing of a loss sustained by a taxpayer attributable to a federally declared disaster. The text of the temporary regulations also serves as the text of the proposed regulations (REG- 150992-13) set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.
2016-10-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUser Fees for Offers in CompromiseThis document contains proposed amendments to the regulations that provide user fees for offers in compromise. The proposed amendments affect taxpayers who wish to pay their liabilities through offers in compromise. The proposed effective date for...2016-24666"https://www.gpo.gov/fdsys/pkg/FR-2016-10-13/pdf/2016-24666.pdfhttps://www.federalregister.gov/documents/2016/10/13/2016-24666/user-fees-for-offers-in-compromiseThis document contains proposed amendments to the regulations that provide user fees for offers in compromise. The proposed amendments affect taxpayers who wish to pay their liabilities through offers in compromise. The proposed effective date for these proposed amendments to the regulations is for offers in compromise submitted on or after February 27, 2017. This document also provides a notice of public hearing on these proposed amendments to the regulations.
2016-10-05Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentLiabilities Recognized as Recourse Partnership Liabilities Under Section 752This document contains proposed regulations that incorporate the text of related temporary regulations and withdraws a portion of a notice of proposed rulemaking (REG-119305-11) to the extent not adopted by final regulations. This document also...2016-23390"https://www.gpo.gov/fdsys/pkg/FR-2016-10-05/pdf/2016-23390.pdfhttps://www.federalregister.gov/documents/2016/10/05/2016-23390/liabilities-recognized-as-recourse-partnership-liabilities-under-section-752This document contains proposed regulations that incorporate the text of related temporary regulations and withdraws a portion of a notice of proposed rulemaking (REG-119305-11) to the extent not adopted by final regulations. This document also contains new proposed regulations addressing when certain obligations to restore a deficit balance in a partner's capital account are disregarded under section 704 of the Internal Revenue Code (Code) and when partnership liabilities are treated as recourse liabilities under section 752. These regulations would affect partnerships and their partners.
2016-10-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentLiabilities Recognized as Recourse Partnership Liabilities Under Section 752This document contains final and temporary regulations concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code (Code) and when certain obligations are recognized for purposes of determining whether a liability...2016-23388"https://www.gpo.gov/fdsys/pkg/FR-2016-10-05/pdf/2016-23388.pdfhttps://www.federalregister.gov/documents/2016/10/05/2016-23388/liabilities-recognized-as-recourse-partnership-liabilities-under-section-752This document contains final and temporary regulations concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code (Code) and when certain obligations are recognized for purposes of determining whether a liability is a recourse partnership liability under section 752. These regulations affect partnerships and their partners. The text of these temporary regulations serves as part of the text of proposed regulations (REG- 122855-15) published in the Proposed Rules section in this issue of the Federal Register.
2016-10-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSection 707 Regarding Disguised Sales, GenerallyThis document contains final regulations under sections 707 and 752 of the Internal Revenue Code (Code). The final regulations under section 707 provide guidance relating to disguised sales of property to or by a partnership and the final regulations...2016-23387"https://www.gpo.gov/fdsys/pkg/FR-2016-10-05/pdf/2016-23387.pdfhttps://www.federalregister.gov/documents/2016/10/05/2016-23387/section-707-regarding-disguised-sales-generallyThis document contains final regulations under sections 707 and 752 of the Internal Revenue Code (Code). The final regulations under section 707 provide guidance relating to disguised sales of property to or by a partnership and the final regulations under section 752 provide guidance relating to allocations of excess nonrecourse liabilities of a partnership to partners for disguised sale purposes. The final regulations affect partnerships and their partners.
2016-10-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Real Estate Investment Trust Real Property; CorrectionThis document contains corrections to final regulations (TD 9784) that were published in the Federal Register on Wednesday, August 31, 2016 (81 FR 59849). The final regulations that clarify the definition of real property for purposes of real estate...2016-23991"https://www.gpo.gov/fdsys/pkg/FR-2016-10-05/pdf/2016-23991.pdfhttps://www.federalregister.gov/documents/2016/10/05/2016-23991/definition-of-real-estate-investment-trust-real-property-correctionThis document contains corrections to final regulations (TD 9784) that were published in the Federal Register on Wednesday, August 31, 2016 (81 FR 59849). The final regulations that clarify the definition of real property for purposes of real estate investment trust provisions of the Internal Revenue Code (Code).
2016-10-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentEstate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; CorrectionThis document contains a correction to a notice of proposed rulemaking (REG-163113-02) that was published in the Federal Register on Thursday, August 4, 2016 (81 FR 51413). The proposed regulations concern the valuation of interests in corporations and...2016-23957"https://www.gpo.gov/fdsys/pkg/FR-2016-10-04/pdf/2016-23957.pdfhttps://www.federalregister.gov/documents/2016/10/04/2016-23957/estate-gift-and-generation-skipping-transfer-taxes-restrictions-on-liquidation-of-an-interestThis document contains a correction to a notice of proposed rulemaking (REG-163113-02) that was published in the Federal Register on Thursday, August 4, 2016 (81 FR 51413). The proposed regulations concern the valuation of interests in corporations and partnerships for estate, gift, and generation-skipping transfer tax purposes.
2016-10-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCredit for Increasing Research ActivitiesThis document contains final regulations concerning the application of the credit for increasing research activities. These final regulations provide guidance on software that is developed by (or for the benefit of) the taxpayer primarily for internal...2016-23174"https://www.gpo.gov/fdsys/pkg/FR-2016-10-04/pdf/2016-23174.pdfhttps://www.federalregister.gov/documents/2016/10/04/2016-23174/credit-for-increasing-research-activitiesThis document contains final regulations concerning the application of the credit for increasing research activities. These final regulations provide guidance on software that is developed by (or for the benefit of) the taxpayer primarily for internal use by the taxpayer (internal use software). These final regulations also include examples to illustrate the application of the process of experimentation requirement to software. These final regulations will affect taxpayers engaged in research activities involving software.
2016-09-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance under Section 851 Relating to Investments in Stock and SecuritiesThis document provides guidance relating to the income test and the asset diversification requirements that are used to determine whether a corporation may qualify as a regulated investment company (RIC) for federal income tax purposes. These proposed...2016-23408"https://www.gpo.gov/fdsys/pkg/FR-2016-09-28/pdf/2016-23408.pdfhttps://www.federalregister.gov/documents/2016/09/28/2016-23408/guidance-under-section-851-relating-to-investments-in-stock-and-securitiesThis document provides guidance relating to the income test and the asset diversification requirements that are used to determine whether a corporation may qualify as a regulated investment company (RIC) for federal income tax purposes. These proposed regulations provide guidance to corporations that intend to qualify as RICs.
2016-09-26Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting for Qualified Tuition and Related Expenses; Education Tax Credits; CorrectionThis document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-131418-14) that was published in the Federal Register on Tuesday, August 2, 2016 (81 FR 50657). The proposed regulations that revise the rules for...2016-22938"https://www.gpo.gov/fdsys/pkg/FR-2016-09-26/pdf/2016-22938.pdfhttps://www.federalregister.gov/documents/2016/09/26/2016-22938/reporting-for-qualified-tuition-and-related-expenses-education-tax-credits-correctionThis document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-131418-14) that was published in the Federal Register on Tuesday, August 2, 2016 (81 FR 50657). The proposed regulations that revise the rules for reporting qualified tuition and related expenses under section 6050S on a Form 1098-T, ``Tuition Statement,'' and conforms the regulations to the changes made to section 6050S by the Protecting Americans from Tax Hikes Act of 2015.
2016-09-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Inclusion When Lessee Treated as Having Acquired Investment Credit Property; CorrectionThis document contains a correction to temporary regulations (TD 9776) that were published in the Federal Register on July 22, 2016 (81 FR 47701). The temporary regulations provide guidance regarding the income inclusion rules under section 50(d)(5) of...2016-22945"https://www.gpo.gov/fdsys/pkg/FR-2016-09-23/pdf/2016-22945.pdfhttps://www.federalregister.gov/documents/2016/09/23/2016-22945/income-inclusion-when-lessee-treated-as-having-acquired-investment-credit-property-correctionThis document contains a correction to temporary regulations (TD 9776) that were published in the Federal Register on July 22, 2016 (81 FR 47701). The temporary regulations provide guidance regarding the income inclusion rules under section 50(d)(5) of the Internal Revenue Code (Code) that are applicable to a lessee of investment credit property when a lessor of such property elects to treat the lessee as having acquired the property.
2016-09-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRequirement To Notify the IRS of Intent To Operate as a Section 501(c)(4) Organization; CorrectionThis document contains a correction to final and temporary regulations (TD 9775) that were published in the Federal Register on July 12, 2016 (81 FR 45008). The final and temporary regulations are relating to the requirement, added by the Protecting...2016-22939"https://www.gpo.gov/fdsys/pkg/FR-2016-09-23/pdf/2016-22939.pdfhttps://www.federalregister.gov/documents/2016/09/23/2016-22939/requirement-to-notify-the-irs-of-intent-to-operate-as-a-section-501c4-organization-correctionThis document contains a correction to final and temporary regulations (TD 9775) that were published in the Federal Register on July 12, 2016 (81 FR 45008). The final and temporary regulations are relating to the requirement, added by the Protecting Americans from Tax Hikes Act of 2015, that organizations must notify the IRS of their intent to operate under section 501(c)(4) of the Internal Revenue Code.
2016-09-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMethod of Accounting for Gains and Losses on Shares in Money Market Funds; Broker Returns With Respect to Sales of Shares in Money Market Funds; CorrectionThis document contains a correction to final regulations (TD 9774) that were published in the Federal Register on July 8, 2016 (81 FR 44508). The final regulations provide a simplified method of accounting for gains and losses on shares in money market...2016-22950"https://www.gpo.gov/fdsys/pkg/FR-2016-09-23/pdf/2016-22950.pdfhttps://www.federalregister.gov/documents/2016/09/23/2016-22950/method-of-accounting-for-gains-and-losses-on-shares-in-money-market-funds-broker-returns-withThis document contains a correction to final regulations (TD 9774) that were published in the Federal Register on July 8, 2016 (81 FR 44508). The final regulations provide a simplified method of accounting for gains and losses on shares in money market funds (MMFs). The final regulations also provide guidance regarding information reporting requirements for shares in MMFs.
2016-09-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCountry-by-Country Reporting; CorrectionThis document contains corrections to final regulations (TD 9773) that were published in the Federal Register on Thursday, June 30, 2016 (81 FR 42482). This document contains final regulations that require annual country-by-country reporting by certain...2016-22440"https://www.gpo.gov/fdsys/pkg/FR-2016-09-19/pdf/2016-22440.pdfhttps://www.federalregister.gov/documents/2016/09/19/2016-22440/country-by-country-reporting-correctionThis document contains corrections to final regulations (TD 9773) that were published in the Federal Register on Thursday, June 30, 2016 (81 FR 42482). This document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.
2016-09-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPremium Tax Credit NPRM VI; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-109086-15) published in the Federal Register on Friday, July 8, 2015 (81 FR 44557). The proposed regulations related to the health insurance premium tax credit (premium tax...2016-22067"https://www.gpo.gov/fdsys/pkg/FR-2016-09-14/pdf/2016-22067.pdfhttps://www.federalregister.gov/documents/2016/09/14/2016-22067/premium-tax-credit-nprm-vi-correctionThis document contains corrections to a notice of proposed rulemaking (REG-109086-15) published in the Federal Register on Friday, July 8, 2015 (81 FR 44557). The proposed regulations related to the health insurance premium tax credit (premium tax credit) and the individual shared responsibility provision. These proposed regulations affect individuals who enroll in qualified health plans through Health Insurance Exchanges (Exchanges, also called Marketplaces) and claim the premium tax credit, and Exchanges that make qualified health plan available to individuals and employers.
2016-09-09RuleDEPARTMENT OF THE TREASURYTreasury DepartmentModifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension PlansThis document contains final regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These regulations change the regulations regarding the minimum present value...2016-21393"https://www.gpo.gov/fdsys/pkg/FR-2016-09-09/pdf/2016-21393.pdfhttps://www.federalregister.gov/documents/2016/09/09/2016-21393/modifications-to-minimum-present-value-requirements-for-partial-annuity-distribution-options-underThis document contains final regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These regulations change the regulations regarding the minimum present value requirements for defined benefit plan distributions to permit plans to simplify the treatment of certain optional forms of benefit that are paid partly in the form of an annuity and partly in a single sum or other more accelerated form. These regulations affect participants, beneficiaries, sponsors, and administrators of defined benefit pension plans.
2016-09-02RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Terms Relating to Marital StatusThis document contains final regulations that reflect the holdings of Obergefell v. Hodges, 576 U.S. ___, 135 S. Ct. 2584 (2015), Windsor v. United States, 570 U.S. ___, 133 S. Ct. 2675 (2013), and Revenue Ruling 2013-17 (2013-38 IRB 201), and that...2016-21096"https://www.gpo.gov/fdsys/pkg/FR-2016-09-02/pdf/2016-21096.pdfhttps://www.federalregister.gov/documents/2016/09/02/2016-21096/definition-of-terms-relating-to-marital-statusThis document contains final regulations that reflect the holdings of Obergefell v. Hodges, 576 U.S. ___, 135 S. Ct. 2584 (2015), Windsor v. United States, 570 U.S. ___, 133 S. Ct. 2675 (2013), and Revenue Ruling 2013-17 (2013-38 IRB 201), and that define terms in the Internal Revenue Code describing the marital status of taxpayers for federal tax purposes.
2016-08-31RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Real Estate Investment Trust Real PropertyThis document contains final regulations that clarify the definition of real property for purposes of the real estate investment trust provisions of the Internal Revenue Code (Code). These final regulations provide guidance to real estate investment...2016-20987"https://www.gpo.gov/fdsys/pkg/FR-2016-08-31/pdf/2016-20987.pdfhttps://www.federalregister.gov/documents/2016/08/31/2016-20987/definition-of-real-estate-investment-trust-real-propertyThis document contains final regulations that clarify the definition of real property for purposes of the real estate investment trust provisions of the Internal Revenue Code (Code). These final regulations provide guidance to real estate investment trusts and their shareholders.
2016-08-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Guidance for Tax-Exempt Bonds; CorrectionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue...2016-20087"https://www.gpo.gov/fdsys/pkg/FR-2016-08-23/pdf/2016-20087.pdfhttps://www.federalregister.gov/documents/2016/08/23/2016-20087/arbitrage-guidance-for-tax-exempt-bonds-correctionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue Code applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments.
2016-08-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Guidance for Tax-Exempt Bonds; CorrectionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue...2016-20086"https://www.gpo.gov/fdsys/pkg/FR-2016-08-23/pdf/2016-20086.pdfhttps://www.federalregister.gov/documents/2016/08/23/2016-20086/arbitrage-guidance-for-tax-exempt-bonds-correctionThis document contains corrections to final regulations (TD 9777) that were published in the Federal Register on Monday, July 18, 2016 (81 FR 46582). The final regulations relate to the arbitrage restrictions under section 148 of the Internal Revenue Code applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments.
2016-08-22Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUser Fees for Installment AgreementsThis document contains proposed amendments to the regulations that provide user fees for installment agreements. The proposed amendments affect taxpayers who wish to pay their liabilities through installment agreements. The proposed effective date for...2016-19836"https://www.gpo.gov/fdsys/pkg/FR-2016-08-22/pdf/2016-19836.pdfhttps://www.federalregister.gov/documents/2016/08/22/2016-19836/user-fees-for-installment-agreementsThis document contains proposed amendments to the regulations that provide user fees for installment agreements. The proposed amendments affect taxpayers who wish to pay their liabilities through installment agreements. The proposed effective date for these proposed amendments to the regulations is January 1, 2017. This document also provides a notice of public hearing on these proposed amendments to the regulations.
2016-08-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTax on Certain Foreign ProcurementThis document contains final regulations under section 5000C of the Internal Revenue Code relating to the 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. The regulations affect U.S. government...2016-19452"https://www.gpo.gov/fdsys/pkg/FR-2016-08-18/pdf/2016-19452.pdfhttps://www.federalregister.gov/documents/2016/08/18/2016-19452/tax-on-certain-foreign-procurementThis document contains final regulations under section 5000C of the Internal Revenue Code relating to the 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. The regulations affect U.S. government acquiring agencies and foreign persons providing certain goods or services to the U.S. government pursuant to a contract. This document also contains final regulations under section 6114, with respect to foreign persons claiming an exemption from the 2 percent tax under an income tax treaty.
2016-08-10RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPreparer Tax Identification Number (PTIN) User Fee UpdateThis document contains final regulations relating to the imposition of certain user fees on tax return preparers. The final regulations supersede and adopt the text of temporary regulations that reduced the user fee to apply for or renew a preparer tax...2016-18925"https://www.gpo.gov/fdsys/pkg/FR-2016-08-10/pdf/2016-18925.pdfhttps://www.federalregister.gov/documents/2016/08/10/2016-18925/preparer-tax-identification-number-ptin-user-fee-updateThis document contains final regulations relating to the imposition of certain user fees on tax return preparers. The final regulations supersede and adopt the text of temporary regulations that reduced the user fee to apply for or renew a preparer tax identification number (PTIN) from $50 to $33. The final regulations affect individuals who apply for or renew a PTIN. The Independent Offices Appropriations Act of 1952 authorizes the charging of user fees.
2016-08-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElection Into the Partnership Audit Regime Under the Bipartisan Budget Act of 2015This document contains temporary regulations pursuant to section 1101(g)(4) of the Bipartisan Budget Act of 2015 regarding an election to apply the new partnership audit regime enacted by that act to certain returns of a partnership. The regulations...2016-18638"https://www.gpo.gov/fdsys/pkg/FR-2016-08-05/pdf/2016-18638.pdfhttps://www.federalregister.gov/documents/2016/08/05/2016-18638/election-into-the-partnership-audit-regime-under-the-bipartisan-budget-act-of-2015This document contains temporary regulations pursuant to section 1101(g)(4) of the Bipartisan Budget Act of 2015 regarding an election to apply the new partnership audit regime enacted by that act to certain returns of a partnership. The regulations provide the time, form, and manner for making this election. The regulations affect any partnership that wishes to elect to have the new partnership audit regime apply to its returns filed for certain taxable years beginning before January 1, 2018.
2016-08-05Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentElection Into the Partnership Audit Regime Under the Bipartisan Budget Act of 2015This document contains proposed regulations pursuant to section 1101(g)(4) of the Bipartisan Budget Act of 2015 regarding an election to apply the new partnership audit regime enacted by that act to certain returns of a partnership. The regulations...2016-18632"https://www.gpo.gov/fdsys/pkg/FR-2016-08-05/pdf/2016-18632.pdfhttps://www.federalregister.gov/documents/2016/08/05/2016-18632/election-into-the-partnership-audit-regime-under-the-bipartisan-budget-act-of-2015This document contains proposed regulations pursuant to section 1101(g)(4) of the Bipartisan Budget Act of 2015 regarding an election to apply the new partnership audit regime enacted by that act to certain returns of a partnership. The regulations provide the time, form, and manner for making this election. The regulations affect any partnership that wishes to elect to have the new partnership audit regime apply to its returns filed for certain taxable years beginning before January 1, 2018.
2016-08-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentEstate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an InterestThis document contains proposed regulations concerning the valuation of interests in corporations and partnerships for estate, gift, and generation-skipping transfer (GST) tax purposes. Specifically, these proposed regulations concern the treatment of...2016-18370"https://www.gpo.gov/fdsys/pkg/FR-2016-08-04/pdf/2016-18370.pdfhttps://www.federalregister.gov/documents/2016/08/04/2016-18370/estate-gift-and-generation-skipping-transfer-taxes-restrictions-on-liquidation-of-an-interestThis document contains proposed regulations concerning the valuation of interests in corporations and partnerships for estate, gift, and generation-skipping transfer (GST) tax purposes. Specifically, these proposed regulations concern the treatment of certain lapsing rights and restrictions on liquidation in determining the value of the transferred interests. These proposed regulations affect certain transferors of interests in corporations and partnerships and are necessary to prevent the undervaluation of such transferred interests.
2016-08-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentApplication of Section 409A to Nonqualified Deferred Compensation Plans; CorrectionThis document contains corrections to a partial withdrawal of notice of proposed rulemaking; notice of proposed rulemaking (REG- 123854-12) that was published in the Federal Register on Wednesday, June 22, 2016 (81 FR 40569). The proposed regulations...2016-18355"https://www.gpo.gov/fdsys/pkg/FR-2016-08-04/pdf/2016-18355.pdfhttps://www.federalregister.gov/documents/2016/08/04/2016-18355/application-of-section-409a-to-nonqualified-deferred-compensation-plans-correctionThis document contains corrections to a partial withdrawal of notice of proposed rulemaking; notice of proposed rulemaking (REG- 123854-12) that was published in the Federal Register on Wednesday, June 22, 2016 (81 FR 40569). The proposed regulations are to clarify or modify certain specific provisions of the final regulations under section 409A (TD 9321, 72 FR 19234).
2016-08-02Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInformation Reporting of Catastrophic Health Coverage and Other Issues Under Section 6055This document contains proposed regulations relating to information reporting of minimum essential coverage under section 6055 of the Internal Revenue Code (Code). Health insurance issuers, certain employers, and others that provide minimum essential...2016-18100"https://www.gpo.gov/fdsys/pkg/FR-2016-08-02/pdf/2016-18100.pdfhttps://www.federalregister.gov/documents/2016/08/02/2016-18100/information-reporting-of-catastrophic-health-coverage-and-other-issues-under-section-6055This document contains proposed regulations relating to information reporting of minimum essential coverage under section 6055 of the Internal Revenue Code (Code). Health insurance issuers, certain employers, and others that provide minimum essential coverage to individuals must report to the IRS information about the type and period of coverage and furnish related statements to covered individuals. These proposed regulations affect health insurance issuers, employers, governments, and other persons that provide minimum essential coverage to individuals.
2016-08-02Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting for Qualified Tuition and Related Expenses; Education Tax CreditsThis document contains proposed regulations that revise the rules for reporting qualified tuition and related expenses under section 6050S on a Form 1098-T, ``Tuition Statement,'' and conforms the regulations to the changes made to section 6050S by the...2016-18032"https://www.gpo.gov/fdsys/pkg/FR-2016-08-02/pdf/2016-18032.pdfhttps://www.federalregister.gov/documents/2016/08/02/2016-18032/reporting-for-qualified-tuition-and-related-expenses-education-tax-creditsThis document contains proposed regulations that revise the rules for reporting qualified tuition and related expenses under section 6050S on a Form 1098-T, ``Tuition Statement,'' and conforms the regulations to the changes made to section 6050S by the Protecting Americans from Tax Hikes Act of 2015. This document also seeks to amend the regulations on the education tax credits under section 25A generally as well as to conform the regulations to changes made to section 25A by the Trade Preferences Extension Act of 2015 and the Protecting Americans from Tax Hikes Act of 2015. The proposed regulations affect certain higher educational institutions required to file Form 1098-T and taxpayers eligible to claim an education tax credit. This document also provides notice of a public hearing on these proposed regulations.
2016-07-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentProperty Transferred in Connection With the Performance of ServicesThis document contains final regulations relating to property transferred in connection with the performance of services. These final regulations affect certain taxpayers who receive property transferred in connection with the performance of services...2016-17591"https://www.gpo.gov/fdsys/pkg/FR-2016-07-26/pdf/2016-17591.pdfhttps://www.federalregister.gov/documents/2016/07/26/2016-17591/property-transferred-in-connection-with-the-performance-of-servicesThis document contains final regulations relating to property transferred in connection with the performance of services. These final regulations affect certain taxpayers who receive property transferred in connection with the performance of services and make an election to include the value of substantially nonvested property in income in the year of transfer.
2016-07-22Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Inclusion When Lessee Treated as Having Acquired Investment Credit PropertyThis document withdraws the notice of proposed rulemaking published in the Federal Register on December 20, 1985, and the notice of proposed rulemaking published in the Federal Register on September 21, 1987. In the Rules and Regulations section of...2016-16561"https://www.gpo.gov/fdsys/pkg/FR-2016-07-22/pdf/2016-16561.pdfhttps://www.federalregister.gov/documents/2016/07/22/2016-16561/income-inclusion-when-lessee-treated-as-having-acquired-investment-credit-propertyThis document withdraws the notice of proposed rulemaking published in the Federal Register on December 20, 1985, and the notice of proposed rulemaking published in the Federal Register on September 21, 1987. In the Rules and Regulations section of this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations relating to the income inclusion rules under section 50(d)(5) of the Internal Revenue Code (Code) that are applicable to a lessee of investment credit property when a lessor of such property elects to treat the lessee as having acquired the property. The text of those regulations also serves as the text of these proposed regulations.
2016-07-22Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCoverage for Contraceptive ServicesThis document is a request for information on whether there are alternative ways (other than those offered in current regulations) for eligible organizations that object to providing coverage for contraceptive services on religious grounds to obtain an...2016-17242"https://www.gpo.gov/fdsys/pkg/FR-2016-07-22/pdf/2016-17242.pdfhttps://www.federalregister.gov/documents/2016/07/22/2016-17242/coverage-for-contraceptive-servicesThis document is a request for information on whether there are alternative ways (other than those offered in current regulations) for eligible organizations that object to providing coverage for contraceptive services on religious grounds to obtain an accommodation, while still ensuring that women enrolled in the organizations' health plans have access to seamless coverage of the full range of Food and Drug Administration-approved contraceptives without cost sharing. This information is being solicited in light of the Supreme Court's opinion in Zubik v. Burwell, 136 S. Ct. 1557 (2016). The Departments of Health and Human Services (HHS), Labor, and the Treasury (collectively, the Departments) invite public comments via this request for information.
2016-07-22RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Inclusion When Lessee Treated as Having Acquired Investment Credit PropertyThis document contains temporary regulations that provide guidance regarding the income inclusion rules under section 50(d)(5) of the Internal Revenue Code (Code) that are applicable to a lessee of investment credit property when a lessor of such...2016-16563"https://www.gpo.gov/fdsys/pkg/FR-2016-07-22/pdf/2016-16563.pdfhttps://www.federalregister.gov/documents/2016/07/22/2016-16563/income-inclusion-when-lessee-treated-as-having-acquired-investment-credit-propertyThis document contains temporary regulations that provide guidance regarding the income inclusion rules under section 50(d)(5) of the Internal Revenue Code (Code) that are applicable to a lessee of investment credit property when a lessor of such property elects to treat the lessee as having acquired the property. These temporary regulations also provide rules to coordinate the section 50(a) recapture rules with the section 50(d)(5) income inclusion rules. In addition, these temporary regulations provide rules regarding income inclusion upon a lease termination, lease disposition by a lessee, or disposition of a partner's or S corporation shareholder's entire interest in a lessee partnership or S corporation outside of the recapture period. Accordingly, these regulations will affect lessees of investment credit property when the lessor of such property makes an election to treat the lessee as having acquired the property and an investment credit is determined under section 46 with respect to such lessee. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register.
2016-07-21Proposed RuleDEPARTMENT OF LABORLabor DepartmentProposed Revision of Annual Information Return/ReportsThis document contains proposed changes to the Form 5500 Annual Return/Report forms, including the Form 5500, Annual Return/ Report of Employee Benefit Plan (Form 5500 Annual Return/Report), and the Form 5500-SF, Short Form Annual Return/Report of...2016-14893"https://www.gpo.gov/fdsys/pkg/FR-2016-07-21/pdf/2016-14893.pdfhttps://www.federalregister.gov/documents/2016/07/21/2016-14893/proposed-revision-of-annual-information-returnreportsThis document contains proposed changes to the Form 5500 Annual Return/Report forms, including the Form 5500, Annual Return/ Report of Employee Benefit Plan (Form 5500 Annual Return/Report), and the Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan (Form 5500-SF). The annual returns/reports are filed for employee pension and welfare benefit plans under the Employee Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code (Code). The proposed revisions in this Notice reflect efforts of the Department of Labor, the Internal Revenue Service, and the Pension Benefit Guaranty Corporation (collectively Agencies) to improve employee benefit plan reporting for filers, the public, and the Agencies by modernizing financial information filed regarding plans; updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirements with the Department of Labor's final disclosure requirements enhancing mineability of data filed on annual return/reports; requiring reporting by all group health plans covered by Title I of ERISA, including adding a new Schedule J (Group Health Plan Information); and improving compliance under ERISA and the Code through selected new questions regarding plan operations, service provider relationships, and financial management of the plan. These revisions, which are being proposed in conjunction with a recompete of the ERISA Filing and Acceptance System (EFAST2) contract, if adopted, generally would apply for plan years beginning on or after January 1, 2019. EFAST2 is expected to begin processing the Plan Year 2019 Form 5500 Annual Return/Report beginning January 1, 2020. The proposed revisions would affect employee pension and welfare benefit plans, plan sponsors, administrators, and service providers to plans subject to annual reporting requirements under ERISA and the Code.
2016-07-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related Transactions; CorrectionThis document contains corrections to a correction document for final and temporary regulations (TD 9761) that was published in the Federal Register on June 23, 2016 (81 FR 40810).2016-16470"https://www.gpo.gov/fdsys/pkg/FR-2016-07-19/pdf/2016-16470.pdfhttps://www.federalregister.gov/documents/2016/07/19/2016-16470/inversions-and-related-transactions-correctionThis document contains corrections to a correction document for final and temporary regulations (TD 9761) that was published in the Federal Register on June 23, 2016 (81 FR 40810).
2016-07-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentArbitrage Guidance for Tax-Exempt BondsThis document contains final regulations on the arbitrage restrictions under section 148 of the Internal Revenue Code (Code) applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments. These final regulations...2016-16558"https://www.gpo.gov/fdsys/pkg/FR-2016-07-18/pdf/2016-16558.pdfhttps://www.federalregister.gov/documents/2016/07/18/2016-16558/arbitrage-guidance-for-tax-exempt-bondsThis document contains final regulations on the arbitrage restrictions under section 148 of the Internal Revenue Code (Code) applicable to tax-exempt bonds and other tax-advantaged bonds issued by State and local governments. These final regulations amend existing regulations to address certain market developments, simplify certain provisions, address certain technical issues, and make existing regulations more administrable. These final regulations affect State and local governments that issue tax-exempt and other tax-advantaged bonds.
2016-07-15Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Under Section 355 Concerning Device and Active Trade or BusinessThis document contains proposed regulations under section 355 of the Internal Revenue Code (Code). The proposed regulations would clarify the application of the device prohibition and the active business requirement of section 355. The proposed...2016-16512"https://www.gpo.gov/fdsys/pkg/FR-2016-07-15/pdf/2016-16512.pdfhttps://www.federalregister.gov/documents/2016/07/15/2016-16512/guidance-under-section-355-concerning-device-and-active-trade-or-businessThis document contains proposed regulations under section 355 of the Internal Revenue Code (Code). The proposed regulations would clarify the application of the device prohibition and the active business requirement of section 355. The proposed regulations would affect corporations that distribute the stock of controlled corporations, their shareholders, and their security holders.
2016-07-14RuleDEPARTMENT OF THE TREASURYTreasury DepartmentParticipation of a Person Described in Section 6103(n) in a Summons Interview Under Section 7602(a)(2) of the Internal Revenue CodeThis document contains final regulations modifying regulations under section 7602(a) of the Internal Revenue Code relating to administrative summonses. Specifically, these final regulations clarify that persons with whom the IRS or the Office of Chief...2016-16606"https://www.gpo.gov/fdsys/pkg/FR-2016-07-14/pdf/2016-16606.pdfhttps://www.federalregister.gov/documents/2016/07/14/2016-16606/participation-of-a-person-described-in-section-6103n-in-a-summons-interview-under-section-7602a2-ofThis document contains final regulations modifying regulations under section 7602(a) of the Internal Revenue Code relating to administrative summonses. Specifically, these final regulations clarify that persons with whom the IRS or the Office of Chief Counsel (Chief Counsel) contracts for services described in section 6103(n) and its implementing regulations may be included as persons designated to receive summoned books, papers, records, or other data and, in the presence and under the guidance of an IRS officer or employee, participate fully in the interview of a witness summoned by the IRS to provide testimony under oath. These regulations may affect taxpayers, a taxpayer's officers or employees, and any third party who is served with a summons, as well as any other person entitled to notice of a summons.
2016-07-12RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRequirement To Notify the IRS of Intent To Operate as a Section 501(c)(4) Organization; Final and Temporary RegulationsThis document contains final and temporary regulations relating to the requirement, added by the Protecting Americans from Tax Hikes Act of 2015, that organizations must notify the IRS of their intent to operate under section 501(c)(4) of the Internal...2016-16338"https://www.gpo.gov/fdsys/pkg/FR-2016-07-12/pdf/2016-16338.pdfhttps://www.federalregister.gov/documents/2016/07/12/2016-16338/requirement-to-notify-the-irs-of-intent-to-operate-as-a-section-501c4-organization-final-andThis document contains final and temporary regulations relating to the requirement, added by the Protecting Americans from Tax Hikes Act of 2015, that organizations must notify the IRS of their intent to operate under section 501(c)(4) of the Internal Revenue Code (Code). The regulations affect organizations described in section 501(c)(4) (section 501(c)(4) organizations) that are organized after December 18, 2015, and certain section 501(c)(4) organizations existing on that date. The text of the temporary regulations serves as the text of the proposed regulations set forth in the related notice of proposed rulemaking (REG-101689-16) published in the Proposed Rules section in this issue of the Federal Register.
2016-07-12Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRequirement To Notify the IRS of Intent To Operate as a Section 501(c)(4) OrganizationIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the requirement, added by the Protecting Americans from Tax Hikes Act of 2015, that organizations must notify the IRS of...2016-16337"https://www.gpo.gov/fdsys/pkg/FR-2016-07-12/pdf/2016-16337.pdfhttps://www.federalregister.gov/documents/2016/07/12/2016-16337/requirement-to-notify-the-irs-of-intent-to-operate-as-a-section-501c4-organizationIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the requirement, added by the Protecting Americans from Tax Hikes Act of 2015, that organizations must notify the IRS of their intent to operate under section 501(c)(4) of the Internal Revenue Code (Code). The text of those temporary regulations also serves as the text of these proposed regulations.
2016-07-12RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertified Professional Employer Organizations; CorrectionThis document contains corrections to final and temporary regulations (TD 9768) that were published in the Federal Register on May 6, 2016 (81 FR 27315). The final and temporary regulations are relating to certified professional employer organizations...2016-16400"https://www.gpo.gov/fdsys/pkg/FR-2016-07-12/pdf/2016-16400.pdfhttps://www.federalregister.gov/documents/2016/07/12/2016-16400/certified-professional-employer-organizations-correctionThis document contains corrections to final and temporary regulations (TD 9768) that were published in the Federal Register on May 6, 2016 (81 FR 27315). The final and temporary regulations are relating to certified professional employer organizations (CPEOs). The Stephen Beck, Jr. Achieving a Better Life Experience Act of 2014 requires the IRS to establish a voluntary certification program for professional employer organizations. These final and temporary regulations contain the requirements a person must satisfy in order to become and remain a CPEO.
2016-07-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPremium Tax Credit NPRM VIThis document contains proposed regulations relating to the health insurance premium tax credit (premium tax credit) and the individual shared responsibility provision. These proposed regulations affect individuals who enroll in qualified health plans...2016-15940"https://www.gpo.gov/fdsys/pkg/FR-2016-07-08/pdf/2016-15940.pdfhttps://www.federalregister.gov/documents/2016/07/08/2016-15940/premium-tax-credit-nprm-viThis document contains proposed regulations relating to the health insurance premium tax credit (premium tax credit) and the individual shared responsibility provision. These proposed regulations affect individuals who enroll in qualified health plans through Health Insurance Exchanges (Exchanges, also called Marketplaces) and claim the premium tax credit, and Exchanges that make qualified health plans available to individuals and employers. These proposed regulations also affect individuals who are eligible for employer-sponsored health coverage and individuals who seek to claim an exemption from the individual shared responsibility provision because of unaffordable coverage. Although employers are not directly affected by rules governing the premium tax credit, these proposed regulations may indirectly affect employers through the employer shared responsibility provisions and the related information reporting provisions.
2016-07-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMethod of Accounting for Gains and Losses on Shares in Money Market Funds; Broker Returns With Respect to Sales of Shares in Money Market FundsThis document contains final regulations that provide a simplified method of accounting for gains and losses on shares in money market funds (MMFs). The final regulations also provide guidance regarding information reporting requirements for shares in...2016-16149"https://www.gpo.gov/fdsys/pkg/FR-2016-07-08/pdf/2016-16149.pdfhttps://www.federalregister.gov/documents/2016/07/08/2016-16149/method-of-accounting-for-gains-and-losses-on-shares-in-money-market-funds-broker-returns-withThis document contains final regulations that provide a simplified method of accounting for gains and losses on shares in money market funds (MMFs). The final regulations also provide guidance regarding information reporting requirements for shares in MMFs. The final regulations respond to Securities and Exchange Commission (SEC) rules that change the amount for which certain MMF shares are distributed, redeemed, and repurchased. The final regulations affect MMFs and their shareholders.
2016-07-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSelf-Employment Tax Treatment of Partners in a Partnership That Owns a Disregarded Entity; CorrectionThis document contains a correction to final and temporary regulations (TD 9766) that were published in the Federal Register on May 4, 2016 (81 FR 26693). The final and temporary regulations clarify the employment tax treatment of partners in a...2016-15739"https://www.gpo.gov/fdsys/pkg/FR-2016-07-05/pdf/2016-15739.pdfhttps://www.federalregister.gov/documents/2016/07/05/2016-15739/self-employment-tax-treatment-of-partners-in-a-partnership-that-owns-a-disregarded-entity-correctionThis document contains a correction to final and temporary regulations (TD 9766) that were published in the Federal Register on May 4, 2016 (81 FR 26693). The final and temporary regulations clarify the employment tax treatment of partners in a partnership that owns a disregarded entity.
2016-07-05Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDeemed Distributions Under Section 305(c) of Stock and Rights To Acquire Stock; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-133673-15) that were published in the Federal Register on April 13, 2016 (81 FR 21795). The proposed regulations are in regards to deemed distributions of stock and rights to...2016-15696"https://www.gpo.gov/fdsys/pkg/FR-2016-07-05/pdf/2016-15696.pdfhttps://www.federalregister.gov/documents/2016/07/05/2016-15696/deemed-distributions-under-section-305c-of-stock-and-rights-to-acquire-stock-correctionThis document contains corrections to a notice of proposed rulemaking (REG-133673-15) that were published in the Federal Register on April 13, 2016 (81 FR 21795). The proposed regulations are in regards to deemed distributions of stock and rights to acquire stock. The proposed regulations would resolve ambiguities concerning the amount and timing of deemed distributions that are or result from adjustments to rights to acquire stock.
2016-06-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCountry-by-Country ReportingThis document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group. The final regulations affect United States persons that...2016-15482"https://www.gpo.gov/fdsys/pkg/FR-2016-06-30/pdf/2016-15482.pdfhttps://www.federalregister.gov/documents/2016/06/30/2016-15482/country-by-country-reportingThis document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group. The final regulations affect United States persons that are the ultimate parent entity of a multinational enterprise group that has annual revenue for the preceding annual accounting period of $850,000,000 or more.
2016-06-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]; CorrectionThis document contains a correction to final and temporary regulations (TD 9770) that were published in the Federal Register on June 8, 2016 (81 FR 36793). The final and temporary regulations effect the repeal of the General Utilities doctrine by the...2016-15264"https://www.gpo.gov/fdsys/pkg/FR-2016-06-28/pdf/2016-15264.pdfhttps://www.federalregister.gov/documents/2016/06/28/2016-15264/certain-transfers-of-property-to-regulated-investment-companies-rics-and-real-estate-investmentThis document contains a correction to final and temporary regulations (TD 9770) that were published in the Federal Register on June 8, 2016 (81 FR 36793). The final and temporary regulations effect the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and prevent abuse of the Protecting Americans from Tax Hikes Act of 2015. The temporary regulations impose corporate level tax on certain transactions in which property of a C corporation becomes the property of a REIT.
2016-06-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related Transactions; CorrectionThis document contains corrections to final and temporary regulations (TD 9761) that were published in the Federal Register on April 8, 2016 (81 FR 20858). The temporary regulations address transactions that are structured to avoid the purposes of...2016-14649"https://www.gpo.gov/fdsys/pkg/FR-2016-06-23/pdf/2016-14649.pdfhttps://www.federalregister.gov/documents/2016/06/23/2016-14649/inversions-and-related-transactions-correctionThis document contains corrections to final and temporary regulations (TD 9761) that were published in the Federal Register on April 8, 2016 (81 FR 20858). The temporary regulations address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions.
2016-06-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related Transactions; CorrectionThis document contains corrections to final and temporary regulations (TD 9761) that were published in the Federal Register on April 8, 2016 (81 FR 20858). The temporary regulations address transactions that are structured to avoid the purposes of...2016-14648"https://www.gpo.gov/fdsys/pkg/FR-2016-06-23/pdf/2016-14648.pdfhttps://www.federalregister.gov/documents/2016/06/23/2016-14648/inversions-and-related-transactions-correctionThis document contains corrections to final and temporary regulations (TD 9761) that were published in the Federal Register on April 8, 2016 (81 FR 20858). The temporary regulations address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions.
2016-06-22Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDeferred Compensation Plans of State and Local Governments and Tax-Exempt EntitiesThis document contains proposed regulations prescribing rules under section 457 of the Internal Revenue Code for the taxation of compensation deferred under plans established and maintained by State or local governments or other tax exempt...2016-14329"https://www.gpo.gov/fdsys/pkg/FR-2016-06-22/pdf/2016-14329.pdfhttps://www.federalregister.gov/documents/2016/06/22/2016-14329/deferred-compensation-plans-of-state-and-local-governments-and-tax-exempt-entitiesThis document contains proposed regulations prescribing rules under section 457 of the Internal Revenue Code for the taxation of compensation deferred under plans established and maintained by State or local governments or other tax exempt organizations. These proposed regulations include rules for determining when amounts deferred under these plans are includible in income, the amounts that are includible in income, and the types of plans that are not subject to these rules. The proposed regulations would affect participants, beneficiaries, sponsors, and administrators of certain plans sponsored by State or local governments or tax-exempt organizations that provide for a deferral of compensation. This document also provides a notice of a public hearing on the proposed regulations.
2016-06-22RuleDEPARTMENT OF THE TREASURYTreasury DepartmentModification of Treatment of Certain Health OrganizationsThis document contains final regulations that provide guidance to Blue Cross and Blue Shield organizations, and certain other organizations, on computing and applying the medical loss ratio and the consequences for not meeting the medical loss ratio...2016-14784"https://www.gpo.gov/fdsys/pkg/FR-2016-06-22/pdf/2016-14784.pdfhttps://www.federalregister.gov/documents/2016/06/22/2016-14784/modification-of-treatment-of-certain-health-organizationsThis document contains final regulations that provide guidance to Blue Cross and Blue Shield organizations, and certain other organizations, on computing and applying the medical loss ratio and the consequences for not meeting the medical loss ratio threshold. The final regulations reflect the enactment of a technical correction to section 833(c)(5) of the Internal Revenue Code by the Consolidated and Further Continuing Appropriations Act of 2015. The final regulations affect Blue Cross and Blue Shield organizations, and certain other organizations involved in providing health insurance.
2016-06-22Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentApplication of Section 409A to Nonqualified Deferred Compensation PlansThis document contains proposed regulations that would clarify or modify certain specific provisions of the final regulations under section 409A (TD 9321, 72 FR 19234). This document also withdraws a specific provision of the notice of proposed...2016-14331"https://www.gpo.gov/fdsys/pkg/FR-2016-06-22/pdf/2016-14331.pdfhttps://www.federalregister.gov/documents/2016/06/22/2016-14331/application-of-section-409a-to-nonqualified-deferred-compensation-plansThis document contains proposed regulations that would clarify or modify certain specific provisions of the final regulations under section 409A (TD 9321, 72 FR 19234). This document also withdraws a specific provision of the notice of proposed rulemaking (REG-148326-05) published in the Federal Register on December 8, 2008 (73 FR 74380) regarding the calculation of amounts includible in income under section 409A(a)(1) and replaces that provision with revised proposed regulations. These proposed regulations would affect participants, beneficiaries, sponsors, and administrators of nonqualified deferred compensation plans.
2016-06-21Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of a Certain Interests in Corporations as Stock or Indebtedness; HearingThis document provides a notice of public hearing on proposed regulations under section 385 of the Internal Revenue Code that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock...2016-14734"https://www.gpo.gov/fdsys/pkg/FR-2016-06-21/pdf/2016-14734.pdfhttps://www.federalregister.gov/documents/2016/06/21/2016-14734/treatment-of-a-certain-interests-in-corporations-as-stock-or-indebtedness-hearingThis document provides a notice of public hearing on proposed regulations under section 385 of the Internal Revenue Code that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock in part for federal tax purposes, and establish threshold documentation requirements that must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. The proposed regulations also would treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes.
2016-06-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentConsistent Basis Reporting Between Estate and Person Acquiring Property From Decedent; HearingThis document provides notice of public hearing on the proposed regulations that provide guidance regarding the requirement that a recipient's basis in certain property acquired from a decedent be consistent with the value of the property as finally...2016-14010"https://www.gpo.gov/fdsys/pkg/FR-2016-06-14/pdf/2016-14010.pdfhttps://www.federalregister.gov/documents/2016/06/14/2016-14010/consistent-basis-reporting-between-estate-and-person-acquiring-property-from-decedent-hearingThis document provides notice of public hearing on the proposed regulations that provide guidance regarding the requirement that a recipient's basis in certain property acquired from a decedent be consistent with the value of the property as finally determined for Federal estate tax purposes.
2016-06-10Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExpatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration InsuranceThis document contains proposed regulations on the rules for expatriate health plans, expatriate health plan issuers, and qualified expatriates under the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). This document also includes proposed...2016-13583"https://www.gpo.gov/fdsys/pkg/FR-2016-06-10/pdf/2016-13583.pdfhttps://www.federalregister.gov/documents/2016/06/10/2016-13583/expatriate-health-plans-expatriate-health-plan-issuers-and-qualified-expatriates-excepted-benefitsThis document contains proposed regulations on the rules for expatriate health plans, expatriate health plan issuers, and qualified expatriates under the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). This document also includes proposed conforming amendments to certain regulations to implement the provisions of the EHCCA. Further, this document proposes standards for travel insurance and supplemental health insurance coverage to be considered excepted benefits and revisions to the definition of short-term, limited- duration insurance for purposes of the exclusion from the definition of individual health insurance coverage. These proposed regulations affect expatriates with health coverage under expatriate health plans and sponsors, issuers and administrators of expatriate health plans, individuals with and plan sponsors of travel insurance and supplemental health insurance coverage, and individuals with short-term, limited- duration insurance. In addition, this document proposes to amend a reference in the final regulations relating to prohibitions on lifetime and annual dollar limits and proposes to require that a notice be provided in connection with hospital indemnity and other fixed indemnity insurance in the group health insurance market for it to be considered excepted benefits.
2016-06-10RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Under Section 108(a) Concerning the Exclusion of Section 61(a)(12) Discharge of Indebtedness Income of a Grantor Trust or a Disregarded EntityThis document contains final regulations relating to the exclusion from gross income of discharge of indebtedness income of a grantor trust or an entity that is disregarded as an entity separate from its owner. These final regulations provide rules...2016-13779"https://www.gpo.gov/fdsys/pkg/FR-2016-06-10/pdf/2016-13779.pdfhttps://www.federalregister.gov/documents/2016/06/10/2016-13779/guidance-under-section-108a-concerning-the-exclusion-of-section-61a12-discharge-of-indebtednessThis document contains final regulations relating to the exclusion from gross income of discharge of indebtedness income of a grantor trust or an entity that is disregarded as an entity separate from its owner. These final regulations provide rules regarding the term ``taxpayer'' for purposes of applying the exclusion from gross income of discharge of indebtedness income of a grantor trust or a disregarded entity. These final regulations affect grantor trusts, disregarded entities, and their owners.
2016-06-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]; Final and Temporary RegulationsThis document contains final and temporary regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and preventing abuse of the Protecting Americans from Tax Hikes Act of 2015. The temporary regulations impose...2016-13443"https://www.gpo.gov/fdsys/pkg/FR-2016-06-08/pdf/2016-13443.pdfhttps://www.federalregister.gov/documents/2016/06/08/2016-13443/certain-transfers-of-property-to-regulated-investment-companies-rics-and-real-estate-investmentThis document contains final and temporary regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and preventing abuse of the Protecting Americans from Tax Hikes Act of 2015. The temporary regulations impose corporate level tax on certain transactions in which property of a C corporation becomes the property of a REIT. The temporary regulations affect RICs, REITs, C corporations the property of which becomes the property of a RIC or a REIT, and their shareholders. The text of these temporary regulations also serves as the text of part of the proposed regulations in the related notice of proposed rulemaking (REG-126452-15) set forth in the Proposed Rules section in this issue of the Federal Register.
2016-06-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. The text of those regulations also serves as part...2016-13425"https://www.gpo.gov/fdsys/pkg/FR-2016-06-08/pdf/2016-13425.pdfhttps://www.federalregister.gov/documents/2016/06/08/2016-13425/certain-transfers-of-property-to-regulated-investment-companies-rics-and-real-estate-investmentIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. The text of those regulations also serves as part of the text of these proposed regulations. These proposed regulations would impose corporate level tax on certain transactions in which property of a C corporation becomes the property of a REIT. The proposed regulations also make an amendment not addressed in the temporary regulations. The proposed regulations affect RICs, REITs, C corporations the property of which becomes the property of a RIC or a REIT, and their shareholders.
2016-06-02Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related Transactions; CorrectionThis document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-135734-14) that were published in the Federal Register on Friday, April 8, 2016 (81 FR 20588). The proposed regulations relate to...2016-13015"https://www.gpo.gov/fdsys/pkg/FR-2016-06-02/pdf/2016-13015.pdfhttps://www.federalregister.gov/documents/2016/06/02/2016-13015/inversions-and-related-transactions-correctionThis document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-135734-14) that were published in the Federal Register on Friday, April 8, 2016 (81 FR 20588). The proposed regulations relate to transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions.
2016-05-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRemoval of Allocation Rule for Disbursements From Designated Roth Accounts to Multiple DestinationsThis document contains final regulations eliminating the requirement that each disbursement from a designated Roth account that is directly rolled over to an eligible retirement plan be treated as a separate distribution from any amount paid directly...2016-11647"https://www.gpo.gov/fdsys/pkg/FR-2016-05-18/pdf/2016-11647.pdfhttps://www.federalregister.gov/documents/2016/05/18/2016-11647/removal-of-allocation-rule-for-disbursements-from-designated-roth-accounts-to-multiple-destinationsThis document contains final regulations eliminating the requirement that each disbursement from a designated Roth account that is directly rolled over to an eligible retirement plan be treated as a separate distribution from any amount paid directly to the employee and therefore separately subject to the rule in section 72(e)(2) of the Internal Revenue Code (the Code) allocating pretax and after-tax amounts to each distribution. As a result of this change, if disbursements are made from a taxpayer's designated Roth account to the taxpayer and also to the taxpayer's Roth IRA or designated Roth account in a direct rollover, then pretax amounts will be allocated first to the direct rollover, rather than being allocated pro rata to each destination. Also, a taxpayer will be able to direct the allocation of pretax and after-tax amounts that are included in disbursements from a designated Roth account that are directly rolled over to multiple destinations, applying the same allocation rules to distributions from designated Roth accounts that apply to distributions from other types of accounts. These regulations affect participants in, beneficiaries of, employers maintaining, and administrators of designated Roth accounts under tax-favored retirement plans.
2016-05-10Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038AThis document contains proposed regulations that would treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated...2016-10852"https://www.gpo.gov/fdsys/pkg/FR-2016-05-10/pdf/2016-10852.pdfhttps://www.federalregister.gov/documents/2016/05/10/2016-10852/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-forThis document contains proposed regulations that would treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Internal Revenue Code. These changes are intended to provide the IRS with improved access to information that it needs to satisfy its obligations under U.S. tax treaties, tax information exchange agreements and similar international agreements, as well as to strengthen the enforcement of U.S. tax laws.
2016-05-06Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertified Professional Employer Organizations; Notice of Proposed Rulemaking and Notice of Proposed Rulemaking by Cross-Reference to Temporary RegulationsThis document contains proposed regulations that set forth the Federal employment tax liabilities and other obligations of persons certified by the IRS as certified professional employer organizations (CPEOs) in accordance with provisions enacted as...2016-10702"https://www.gpo.gov/fdsys/pkg/FR-2016-05-06/pdf/2016-10702.pdfhttps://www.federalregister.gov/documents/2016/05/06/2016-10702/certified-professional-employer-organizations-notice-of-proposed-rulemaking-and-notice-of-proposedThis document contains proposed regulations that set forth the Federal employment tax liabilities and other obligations of persons certified by the IRS as certified professional employer organizations (CPEOs) in accordance with provisions enacted as part of The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014. The proposed regulations also propose to adopt, by cross-reference, the text of temporary regulations in the Rules and Regulations section of this issue of the Federal Register, which relate to the requirements for applying for, receiving, and maintaining certification as a CPEO. These proposed regulations will affect persons who apply to be treated as CPEOs and who are certified by the IRS as meeting the applicable requirements. In certain instances, the proposed regulations will also affect the federal employment tax liabilities and other obligations of customers of the CPEO.
2016-05-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCertified Professional Employer Organizations; Final and Temporary RegulationsThis document contains final and temporary regulations relating to certified professional employer organizations (CPEOs). The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 requires the IRS to establish a voluntary certification...2016-10700"https://www.gpo.gov/fdsys/pkg/FR-2016-05-06/pdf/2016-10700.pdfhttps://www.federalregister.gov/documents/2016/05/06/2016-10700/certified-professional-employer-organizations-final-and-temporary-regulationsThis document contains final and temporary regulations relating to certified professional employer organizations (CPEOs). The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 requires the IRS to establish a voluntary certification program for professional employer organizations. These final and temporary regulations contain the requirements a person must satisfy in order to become and remain a CPEO. The final and temporary regulations will affect persons that apply to be CPEOs and are certified by the IRS as meeting the applicable requirements. The text of these final and temporary regulations also serves, in part, as the text of the proposed regulations (REG-127561-15) set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
2016-05-05RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAdditional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014The Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have...2016-10560"https://www.gpo.gov/fdsys/pkg/FR-2016-05-05/pdf/2016-10560.pdfhttps://www.federalregister.gov/documents/2016/05/05/2016-10560/additional-limitation-on-suspension-of-benefits-applicable-to-certain-pension-plans-under-theThe Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have insufficient funds, within a specified timeframe, to pay the full plan benefits to which individuals will be entitled (referred to as plans in ``critical and declining status''). Under MPRA, the sponsor of such a plan is permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions and limitations are satisfied (referred to in MPRA as a ``suspension of benefits''). One specific limitation governs the application of a suspension of benefits under any plan that includes benefits directly attributable to a participant's service with any employer that has withdrawn from the plan in a complete withdrawal, paid its full withdrawal liability, and, pursuant to a collective bargaining agreement, assumed liability for providing benefits to participants and beneficiaries equal to any benefits for such participants and beneficiaries reduced as a result of the financial status of the plan. This document contains final regulations that provide guidance relating to this specific limitation. These regulations affect active, retired, and deferred vested participants and beneficiaries under any such multiemployer plan in critical and declining status as well as employers contributing to, and sponsors and administrators of, those plans.
2016-05-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSelf-Employment Tax Treatment of Partners in a Partnership That Owns a Disregarded EntityIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that clarify the employment tax treatment of partners in a partnership that owns a disregarded entity. These regulations affect...2016-10384"https://www.gpo.gov/fdsys/pkg/FR-2016-05-04/pdf/2016-10384.pdfhttps://www.federalregister.gov/documents/2016/05/04/2016-10384/self-employment-tax-treatment-of-partners-in-a-partnership-that-owns-a-disregarded-entityIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that clarify the employment tax treatment of partners in a partnership that owns a disregarded entity. These regulations affect partners in a partnership that owns a disregarded entity. The text of those temporary regulations serves as the text of these proposed regulations.
2016-05-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSelf-Employment Tax Treatment of Partners in a Partnership That Owns a Disregarded EntityThis document contains final and temporary regulations that clarify the employment tax treatment of partners in a partnership that owns a disregarded entity. These regulations affect partners in a partnership that owns a disregarded entity. The text of...2016-10383"https://www.gpo.gov/fdsys/pkg/FR-2016-05-04/pdf/2016-10383.pdfhttps://www.federalregister.gov/documents/2016/05/04/2016-10383/self-employment-tax-treatment-of-partners-in-a-partnership-that-owns-a-disregarded-entityThis document contains final and temporary regulations that clarify the employment tax treatment of partners in a partnership that owns a disregarded entity. These regulations affect partners in a partnership that owns a disregarded entity. The text of these temporary regulations serves as the text of proposed regulations (REG-114307-15) published in the Proposed Rules section in this issue of the Federal Register.
2016-04-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSuspension of Benefits Under the Multiemployer Pension Reform Act of 2014The Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have...2016-09888"https://www.gpo.gov/fdsys/pkg/FR-2016-04-28/pdf/2016-09888.pdfhttps://www.federalregister.gov/documents/2016/04/28/2016-09888/suspension-of-benefits-under-the-multiemployer-pension-reform-act-of-2014The Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have insufficient funds, within a specified timeframe, to pay the full plan benefits to which individuals will be entitled (referred to as plans in ``critical and declining status''). Under MPRA, the sponsor of a plan in critical and declining status is permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions and limitations are satisfied (referred to in MPRA as a ``suspension of benefits''). MPRA requires the Secretary of the Treasury (Treasury Department), in consultation with the Pension Benefit Guaranty Corporation (PBGC) and the Secretary of Labor (Labor Department), to approve or deny applications by sponsors of these plans to reduce benefits. These regulations affect active, retired, and deferred vested participants and beneficiaries of multiemployer plans that are in critical and declining status as well as employers contributing to, and sponsors and administrators of, those plans.
2016-04-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSection 6708 Failure To Maintain List of Advisees With Respect to Reportable TransactionsThis document contains final regulations relating to the penalty under section 6708 of the Internal Revenue Code for failing to make available lists of advisees with respect to reportable transactions. Section 6708 imposes a penalty upon material...2016-09765"https://www.gpo.gov/fdsys/pkg/FR-2016-04-28/pdf/2016-09765.pdfhttps://www.federalregister.gov/documents/2016/04/28/2016-09765/section-6708-failure-to-maintain-list-of-advisees-with-respect-to-reportable-transactionsThis document contains final regulations relating to the penalty under section 6708 of the Internal Revenue Code for failing to make available lists of advisees with respect to reportable transactions. Section 6708 imposes a penalty upon material advisors for failing to make available to the Secretary, upon written request, the list required to be maintained by section 6112 of the Internal Revenue Code within 20 business days after the date of such request. The final regulations primarily affect individuals and entities who are material advisors, as defined in section 6111 of the Internal Revenue Code.
2016-04-27RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting of Original Issue Discount on Tax-Exempt Obligations; Basis and Transfer Reporting by Securities Brokers for Debt Instruments and Options; CorrectionThis document contains corrections to final regulations (TD 9750) that were published in the Federal Register on Thursday, February 18, 2016 (81 FR 8149). The final regulations relate to information reporting by brokers for transactions involving debt...2016-09697"https://www.gpo.gov/fdsys/pkg/FR-2016-04-27/pdf/2016-09697.pdfhttps://www.federalregister.gov/documents/2016/04/27/2016-09697/reporting-of-original-issue-discount-on-tax-exempt-obligations-basis-and-transfer-reporting-byThis document contains corrections to final regulations (TD 9750) that were published in the Federal Register on Thursday, February 18, 2016 (81 FR 8149). The final regulations relate to information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer's adjusted basis in a debt instrument, and transfer reporting for section 1256 options and debt instruments.
2016-04-27RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting of Original Issue Discount on Tax-Exempt Obligations; Basis and Transfer Reporting by Securities Brokers for Debt Instruments and Options; CorrectionThis document contains corrections to final regulations (TD 9750) that published in the Federal Register on Thursday, February 18, 2016 (81 FR 8149). The final regulations relates to information reporting by brokers for transactions involving debt...2016-09698"https://www.gpo.gov/fdsys/pkg/FR-2016-04-27/pdf/2016-09698.pdfhttps://www.federalregister.gov/documents/2016/04/27/2016-09698/reporting-of-original-issue-discount-on-tax-exempt-obligations-basis-and-transfer-reporting-byThis document contains corrections to final regulations (TD 9750) that published in the Federal Register on Thursday, February 18, 2016 (81 FR 8149). The final regulations relates to information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer's adjusted basis in a debt instrument, and transfer reporting for section 1256 options and debt instruments.
2016-04-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDetermination of Adjusted Applicable Federal Rates Under Section 1288 and the Adjusted Federal Long-Term Rate Under Section 382This document contains final regulations that provide the method to be used to adjust the applicable Federal rates (AFRs) to determine the corresponding rates under section 1288 of the Internal Revenue Code (Code) for tax-exempt obligations (adjusted...2016-09614"https://www.gpo.gov/fdsys/pkg/FR-2016-04-26/pdf/2016-09614.pdfhttps://www.federalregister.gov/documents/2016/04/26/2016-09614/determination-of-adjusted-applicable-federal-rates-under-section-1288-and-the-adjusted-federalThis document contains final regulations that provide the method to be used to adjust the applicable Federal rates (AFRs) to determine the corresponding rates under section 1288 of the Internal Revenue Code (Code) for tax-exempt obligations (adjusted AFRs) and the method to be used to determine the long-term tax-exempt rate and the adjusted Federal long-term rate under section 382. For tax-exempt obligations, the regulations affect the determination of original issue discount under section 1273 and of total unstated interest under section 483. In addition, the regulations affect the determination of the limitations under sections 382 and 383 on the use of certain operating loss carryforwards, tax credits, and other attributes of corporations following ownership changes.
2016-04-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPATH Act Changes to Section 1445; CorrectionThis document contains corrections to final regulations (TD 9721) that were published in the Federal Register on Friday, February 19, 2016 (81 FR 8398). The final regulations are regarding the taxation of, and withholding on, foreign persons upon...2016-09666"https://www.gpo.gov/fdsys/pkg/FR-2016-04-26/pdf/2016-09666.pdfhttps://www.federalregister.gov/documents/2016/04/26/2016-09666/path-act-changes-to-section-1445-correctionThis document contains corrections to final regulations (TD 9721) that were published in the Federal Register on Friday, February 19, 2016 (81 FR 8398). The final regulations are regarding the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, United States real property interests (USRPIs).
2016-04-25RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExamples of Program-Related InvestmentsThis document contains final regulations that provide guidance to private foundations on program-related investments. The final regulations provide a series of examples illustrating investments that qualify as program-related investments. In addition...2016-09396"https://www.gpo.gov/fdsys/pkg/FR-2016-04-25/pdf/2016-09396.pdfhttps://www.federalregister.gov/documents/2016/04/25/2016-09396/examples-of-program-related-investmentsThis document contains final regulations that provide guidance to private foundations on program-related investments. The final regulations provide a series of examples illustrating investments that qualify as program-related investments. In addition to private foundations, these final regulations affect foundation managers who participate in the making of program-related investments.
2016-04-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCountry-by-Country Reporting; HearingThis document provides a notice of public hearing on proposed regulations that would require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.2016-08882"https://www.gpo.gov/fdsys/pkg/FR-2016-04-18/pdf/2016-08882.pdfhttps://www.federalregister.gov/documents/2016/04/18/2016-08882/country-by-country-reporting-hearingThis document provides a notice of public hearing on proposed regulations that would require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.
2016-04-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDeemed Distributions Under Section 305(c) of Stock and Rights to Acquire StockThis document contains proposed regulations regarding deemed distributions of stock and rights to acquire stock. The proposed regulations would resolve ambiguities concerning the amount and timing of deemed distributions that are or result from...2016-08248"https://www.gpo.gov/fdsys/pkg/FR-2016-04-13/pdf/2016-08248.pdfhttps://www.federalregister.gov/documents/2016/04/13/2016-08248/deemed-distributions-under-section-305c-of-stock-and-rights-to-acquire-stockThis document contains proposed regulations regarding deemed distributions of stock and rights to acquire stock. The proposed regulations would resolve ambiguities concerning the amount and timing of deemed distributions that are or result from adjustments to rights to acquire stock. The proposed regulations also would provide additional guidance to withholding agents regarding their current withholding and information reporting obligations under chapters 3 and 4 with respect to these deemed distributions. The proposed regulations would affect corporations issuing rights to acquire stock, their shareholders and holders of these rights, and withholding agents with respect to these deemed distributions.
2016-04-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related TransactionsThis document contains temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations...2016-07300"https://www.gpo.gov/fdsys/pkg/FR-2016-04-08/pdf/2016-07300.pdfhttps://www.federalregister.gov/documents/2016/04/08/2016-07300/inversions-and-related-transactionsThis document contains temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross- references to coordinate the application of the temporary regulations.
2016-04-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPartial Withdrawal of Proposed Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Partial Withdrawal of Proposed Guidance for Determining Stock OwnershipThis document withdraws portions of a notice of proposed rulemaking published in the Federal Register on February 11, 2009. The withdrawn portions relate to the application of section 367(b) to transactions described in section 304(a)(1). This document...2016-07295"https://www.gpo.gov/fdsys/pkg/FR-2016-04-08/pdf/2016-07295.pdfhttps://www.federalregister.gov/documents/2016/04/08/2016-07295/partial-withdrawal-of-proposed-application-of-section-367-to-a-section-351-exchange-resulting-from-aThis document withdraws portions of a notice of proposed rulemaking published in the Federal Register on February 11, 2009. The withdrawn portions relate to the application of section 367(b) to transactions described in section 304(a)(1). This document also withdraws portions of a notice of proposed rulemaking published in the Federal Register on January 17, 2014. The withdrawn portions relate to the identification of certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation for purposes of section 7874.
2016-04-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Interests in Corporations as Stock or IndebtednessThis document contains proposed regulations under section 385 of the Internal Revenue Code (Code) that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock in part for federal tax...2016-07425"https://www.gpo.gov/fdsys/pkg/FR-2016-04-08/pdf/2016-07425.pdfhttps://www.federalregister.gov/documents/2016/04/08/2016-07425/treatment-of-certain-interests-in-corporations-as-stock-or-indebtednessThis document contains proposed regulations under section 385 of the Internal Revenue Code (Code) that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock in part for federal tax purposes, and establish threshold documentation requirements that must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. The proposed regulations also would treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes. The proposed regulations generally affect corporations that issue purported indebtedness to related corporations or partnerships.
2016-04-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentInversions and Related TransactionsThe Department of Treasury (Treasury Department) and the IRS are issuing temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain...2016-07299"https://www.gpo.gov/fdsys/pkg/FR-2016-04-08/pdf/2016-07299.pdfhttps://www.federalregister.gov/documents/2016/04/08/2016-07299/inversions-and-related-transactionsThe Department of Treasury (Treasury Department) and the IRS are issuing temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions in the Rules and Regulations section of this issue of the Federal Register. The temporary regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The text of the temporary regulations also serves as the text of these proposed regulations.
2016-04-01RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIncome Taxes2016-07563"https://www.gpo.gov/fdsys/pkg/FR-2016-04-01/pdf/2016-07563.pdfhttps://www.federalregister.gov/documents/2016/04/01/2016-07563/income-taxes
2016-03-31Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExcise Tax; Tractors, Trailers, Trucks, and Tires; Definition of Highway VehicleThis document contains proposed regulations relating to the excise taxes imposed on the sale of highway tractors, trailers, trucks, and tires; the use of heavy vehicles on the highway; and the definition of highway vehicle related to these and other...2016-06881"https://www.gpo.gov/fdsys/pkg/FR-2016-03-31/pdf/2016-06881.pdfhttps://www.federalregister.gov/documents/2016/03/31/2016-06881/excise-tax-tractors-trailers-trucks-and-tires-definition-of-highway-vehicleThis document contains proposed regulations relating to the excise taxes imposed on the sale of highway tractors, trailers, trucks, and tires; the use of heavy vehicles on the highway; and the definition of highway vehicle related to these and other taxes. These proposed regulations reflect legislative changes and court decisions regarding these topics. These proposed regulations affect manufacturers, producers, importers, dealers, retailers, and users of certain highway tractors, trailers, trucks, and tires.
2016-03-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentLimitations on the Importation of Net Built-In LossesThis document contains final regulations under sections 334(b)(1)(B) and 362(e)(1) of the Internal Revenue Code of 1986 (Code). The regulations apply to certain nonrecognition transfers of loss property to corporations that are subject to certain taxes...2016-06227"https://www.gpo.gov/fdsys/pkg/FR-2016-03-28/pdf/2016-06227.pdfhttps://www.federalregister.gov/documents/2016/03/28/2016-06227/limitations-on-the-importation-of-net-built-in-lossesThis document contains final regulations under sections 334(b)(1)(B) and 362(e)(1) of the Internal Revenue Code of 1986 (Code). The regulations apply to certain nonrecognition transfers of loss property to corporations that are subject to certain taxes under the Code. The regulations affect the corporations receiving such loss property. This document also amends final regulations under sections 332 and 351 to reflect certain statutory changes. The regulations affect certain corporations that transfer assets to, or receive assets from, their shareholders in exchange for the corporation's stock.
2016-03-28RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTax Treatment of Cafeteria Plans2016-07018"https://www.gpo.gov/fdsys/pkg/FR-2016-03-28/pdf/2016-07018.pdfhttps://www.federalregister.gov/documents/2016/03/28/2016-07018/tax-treatment-of-cafeteria-plans
2016-03-22RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIndirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset ReorganizationsThis document contains final regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock...2016-06404"https://www.gpo.gov/fdsys/pkg/FR-2016-03-22/pdf/2016-06404.pdfhttps://www.federalregister.gov/documents/2016/03/22/2016-06404/indirect-stock-transfers-and-the-coordination-rule-exceptions-transfers-of-stock-or-securities-inThis document contains final regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also finalize modifications to the exception to the coordination rule for section 351 exchanges so that it is consistent with the remaining asset reorganization exception. In addition, the regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements. Finally, the regulations finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. These regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges.
2016-03-14Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Political Subdivision; CorrectionThis document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-129067-15) published in the Federal Register on Tuesday, February 23, 2016, (81 FR 8870) that specifies the elements of a political subdivision for...2016-05624"https://www.gpo.gov/fdsys/pkg/FR-2016-03-14/pdf/2016-05624.pdfhttps://www.federalregister.gov/documents/2016/03/14/2016-05624/definition-of-political-subdivision-correctionThis document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-129067-15) published in the Federal Register on Tuesday, February 23, 2016, (81 FR 8870) that specifies the elements of a political subdivision for purposes of tax- exempt bonds. The corrections amend the applicability dates of the proposed definition of political subdivision to provide transition rules with respect to bonds issued before the general applicability date and certain refunding bonds.
2016-03-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentConsistent Basis Reporting Between Estate and Person Acquiring Property From DecedentThis document contains temporary regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (a)(2) before March 31, 2016, need not do so until March 31, 2016....2016-04716"https://www.gpo.gov/fdsys/pkg/FR-2016-03-04/pdf/2016-04716.pdfhttps://www.federalregister.gov/documents/2016/03/04/2016-04716/consistent-basis-reporting-between-estate-and-person-acquiring-property-from-decedentThis document contains temporary regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (a)(2) before March 31, 2016, need not do so until March 31, 2016. These temporary regulations are applicable to executors and other persons who file after July 31, 2015, returns required by section 6018(a) or (b).
2016-03-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentConsistent Basis Reporting Between Estate and Person Acquiring Property From DecedentThis document contains proposed regulations that provide guidance regarding the requirement that a recipient's basis in certain property acquired from a decedent be consistent with the value of the property as finally determined for Federal estate tax...2016-04718"https://www.gpo.gov/fdsys/pkg/FR-2016-03-04/pdf/2016-04718.pdfhttps://www.federalregister.gov/documents/2016/03/04/2016-04718/consistent-basis-reporting-between-estate-and-person-acquiring-property-from-decedentThis document contains proposed regulations that provide guidance regarding the requirement that a recipient's basis in certain property acquired from a decedent be consistent with the value of the property as finally determined for Federal estate tax purposes. In addition, these proposed regulations provide guidance on the reporting requirements for executors or other persons required to file Federal estate tax returns. Temporary regulations in the Rules and Regulations section of this issue of the Federal Register provide transition relief to executors and other persons required to file or furnish certain statements. The text of those temporary regulations (TD 9757) published in the Rules and Regulations section of this issue of the Federal Register also serves as the text of the proposed regulations regarding the transition relief. These proposed regulations as well as TD 9757 published elsewhere in the Rules and Regulations section of this issue of this Federal Register affect executors or other persons who file estate tax returns after July 31, 2015. The proposed regulations also affect beneficiaries who acquire certain property from these estates, and subsequent transferees to whom beneficiaries transfer the property in transactions that do not result in the recognition of gain or loss for Federal income tax purposes.
2016-03-03RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUtility Allowances SubmeteringThis document contains final and temporary regulations that amend the utility allowance regulations concerning the low-income housing credit. The final regulations clarify the circumstances in which utility costs paid by a tenant based on actual...2016-04606"https://www.gpo.gov/fdsys/pkg/FR-2016-03-03/pdf/2016-04606.pdfhttps://www.federalregister.gov/documents/2016/03/03/2016-04606/utility-allowances-submeteringThis document contains final and temporary regulations that amend the utility allowance regulations concerning the low-income housing credit. The final regulations clarify the circumstances in which utility costs paid by a tenant based on actual consumption in a submetered rent-restricted unit are treated as paid by the tenant directly to the utility company. The temporary regulations extend the principles of these submetering rules to situations in which a building owner sells to tenants energy that is produced from a renewable source and that is not delivered by a local utility company. The final and temporary regulations affect owners of low-income housing projects that claim the credit, the tenants in those low-income housing projects, and State and local housing credit agencies. The text of these temporary regulations also serves as the text of the proposed regulations (REG- 123867-14) set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
2016-03-03Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUtility Allowances SubmeteringThis document contains proposed regulations that amend the utility allowance regulations concerning the low-income housing credit. The proposed regulations relate to the circumstances in which utility costs paid by a tenant based on actual consumption...2016-04618"https://www.gpo.gov/fdsys/pkg/FR-2016-03-03/pdf/2016-04618.pdfhttps://www.federalregister.gov/documents/2016/03/03/2016-04618/utility-allowances-submeteringThis document contains proposed regulations that amend the utility allowance regulations concerning the low-income housing credit. The proposed regulations relate to the circumstances in which utility costs paid by a tenant based on actual consumption in a submetered rent-restricted unit are treated as paid by the tenant directly to the utility company. The proposed regulations extend those rules to situations in which a building owner sells to tenants energy that is produced from a renewable source and that is not delivered by a local utility company. The proposed regulations affect owners of low-income housing projects that claim the credit, the tenants in those low-income housing projects, and the State and local housing credit agencies that administer the credit. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations concerning utility allowance regulations when the utility is generated from renewable sources and is not delivered by the local utility company. The text of those regulations also serves as the text of these proposed regulations. This document also contains a notice of a public hearing on these proposed regulations.
2016-03-01RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRegulations Under IRC Section 7430 Relating to Awards of Administrative Costs and Attorneys' FeesThis document contains final regulations relating to awards of administrative costs and attorneys' fees. The final regulations conform the regulations to the amendments made in the Taxpayer Relief Act of 1997 and the IRS Restructuring and Reform Act of...2016-04401"https://www.gpo.gov/fdsys/pkg/FR-2016-03-01/pdf/2016-04401.pdfhttps://www.federalregister.gov/documents/2016/03/01/2016-04401/regulations-under-irc-section-7430-relating-to-awards-of-administrative-costs-and-attorneys-feesThis document contains final regulations relating to awards of administrative costs and attorneys' fees. The final regulations conform the regulations to the amendments made in the Taxpayer Relief Act of 1997 and the IRS Restructuring and Reform Act of 1998. The regulations affect taxpayers seeking attorneys' fees and costs.
2016-02-26RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce for Certain Statistical Purposes and Related ActivitiesThis document contains final regulations that authorize the disclosure of certain items of return information to the Bureau of the Census (Bureau) in conformance with section 6103(j)(1) of the Internal Revenue Code (Code). These regulations finalize...2016-04310"https://www.gpo.gov/fdsys/pkg/FR-2016-02-26/pdf/2016-04310.pdfhttps://www.federalregister.gov/documents/2016/02/26/2016-04310/disclosures-of-return-information-reflected-on-returns-to-officers-and-employees-of-the-departmentThis document contains final regulations that authorize the disclosure of certain items of return information to the Bureau of the Census (Bureau) in conformance with section 6103(j)(1) of the Internal Revenue Code (Code). These regulations finalize temporary regulations that were made pursuant to a request from the Secretary of Commerce. These regulations require no action by taxpayers and have no effect on their tax liabilities. Thus, no taxpayers are likely to be affected by the disclosures authorized by this guidance.
2016-02-25Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAmendments to the Low-Income Housing Credit Compliance-Monitoring RegulationsIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing final and temporary regulations concerning the compliance-monitoring duties of a State or local housing credit agency (Agency) for purposes of the low-income...2016-04004"https://www.gpo.gov/fdsys/pkg/FR-2016-02-25/pdf/2016-04004.pdfhttps://www.federalregister.gov/documents/2016/02/25/2016-04004/amendments-to-the-low-income-housing-credit-compliance-monitoring-regulationsIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing final and temporary regulations concerning the compliance-monitoring duties of a State or local housing credit agency (Agency) for purposes of the low-income housing credit. The final and temporary regulations revise and clarify certain rules relating to the requirements to conduct physical inspections and review low-income certifications and other documentation. The text of the temporary regulations also serves as the text of these proposed regulations.
2016-02-25RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAmendments to the Low-Income Housing Credit Compliance-Monitoring RegulationsThis document contains final and temporary regulations relating to the compliance-monitoring duties of a State or local housing credit agency for purposes of the low-income housing credit. The final and temporary regulations revise and clarify the...2016-04005"https://www.gpo.gov/fdsys/pkg/FR-2016-02-25/pdf/2016-04005.pdfhttps://www.federalregister.gov/documents/2016/02/25/2016-04005/amendments-to-the-low-income-housing-credit-compliance-monitoring-regulationsThis document contains final and temporary regulations relating to the compliance-monitoring duties of a State or local housing credit agency for purposes of the low-income housing credit. The final and temporary regulations revise and clarify the requirement to conduct physical inspections and review low-income certifications and other documentation. The final and temporary regulations will affect State or local housing credit agencies. The text of these temporary regulations also serves as the text of the proposed regulations (REG-150349-12) set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.
2016-02-24Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCountry-by-Country Reporting; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-109822-15) that was published in the Federal Register on Wednesday, December 23, 2015 (80 FR 79795). The proposed regulations would require annual country-by-country reporting...2016-03906"https://www.gpo.gov/fdsys/pkg/FR-2016-02-24/pdf/2016-03906.pdfhttps://www.federalregister.gov/documents/2016/02/24/2016-03906/country-by-country-reporting-correctionThis document contains corrections to a notice of proposed rulemaking (REG-109822-15) that was published in the Federal Register on Wednesday, December 23, 2015 (80 FR 79795). The proposed regulations would require annual country-by-country reporting by United States persons that are the ultimate parent entity of a multinational enterprise group.
2016-02-23Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Political SubdivisionThis document contains proposed regulations that provide guidance regarding the definition of political subdivision for purposes of tax-exempt bonds. The proposed regulations are necessary to specify the elements of a political subdivision. The...2016-03790"https://www.gpo.gov/fdsys/pkg/FR-2016-02-23/pdf/2016-03790.pdfhttps://www.federalregister.gov/documents/2016/02/23/2016-03790/definition-of-political-subdivisionThis document contains proposed regulations that provide guidance regarding the definition of political subdivision for purposes of tax-exempt bonds. The proposed regulations are necessary to specify the elements of a political subdivision. The proposed regulations will affect State and local governments that issue tax-exempt bonds and users of property financed with tax-exempt bonds. Under certain transition rules, however, the proposed definition of political subdivision will not apply for determining whether outstanding bonds are obligations of a political subdivision and will not apply to existing entities for a transition period. This document also provides a notice of a public hearing for these proposed regulations.
2016-02-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting of Specified Foreign Financial AssetsThis document contains final regulations providing guidance regarding the requirements for certain domestic entities to report specified foreign financial assets to the Internal Revenue Service. These regulations set forth the conditions under which a...2016-03795"https://www.gpo.gov/fdsys/pkg/FR-2016-02-23/pdf/2016-03795.pdfhttps://www.federalregister.gov/documents/2016/02/23/2016-03795/reporting-of-specified-foreign-financial-assetsThis document contains final regulations providing guidance regarding the requirements for certain domestic entities to report specified foreign financial assets to the Internal Revenue Service. These regulations set forth the conditions under which a domestic entity will be considered a specified domestic entity required to undertake such reporting. These regulations affect certain domestic corporations, partnerships, and trusts.
2016-02-19Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRequirements for Type I and Type III Supporting OrganizationsThis document contains proposed regulations regarding the prohibition on certain contributions to Type I and Type III supporting organizations and the requirements for Type III supporting organizations. The regulations reflect changes to the law made...2016-02858"https://www.gpo.gov/fdsys/pkg/FR-2016-02-19/pdf/2016-02858.pdfhttps://www.federalregister.gov/documents/2016/02/19/2016-02858/requirements-for-type-i-and-type-iii-supporting-organizationsThis document contains proposed regulations regarding the prohibition on certain contributions to Type I and Type III supporting organizations and the requirements for Type III supporting organizations. The regulations reflect changes to the law made by the Pension Protection Act of 2006. The regulations will affect Type I and Type III supporting organizations and their supported organizations.
2016-02-19RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPATH Act Changes to Section 1445This document contains final and temporary regulations relating to the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, United States real property interests (USRPIs). The regulations...2016-03421"https://www.gpo.gov/fdsys/pkg/FR-2016-02-19/pdf/2016-03421.pdfhttps://www.federalregister.gov/documents/2016/02/19/2016-03421/path-act-changes-to-section-1445This document contains final and temporary regulations relating to the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, United States real property interests (USRPIs). The regulations reflect changes made by the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act). In addition, the regulations update certain mailing addresses listed in regulations under sections 897 and 1445. These regulations affect certain holders of USRPIs and withholding agents that are required to withhold tax on certain dispositions of, and distributions with respect to, USRPIs. This document also requests comments on certain other aspects of the PATH Act that apply to dispositions of, and distributions with respect to, USRPIs.
2016-02-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReporting of Original Issue Discount on Tax-Exempt Obligations; Basis and Transfer Reporting by Securities Brokers for Debt Instruments and OptionsThis document contains final regulations relating to information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain...2016-03429"https://www.gpo.gov/fdsys/pkg/FR-2016-02-18/pdf/2016-03429.pdfhttps://www.federalregister.gov/documents/2016/02/18/2016-03429/reporting-of-original-issue-discount-on-tax-exempt-obligations-basis-and-transfer-reporting-byThis document contains final regulations relating to information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer's adjusted basis in a debt instrument, and transfer reporting for section 1256 options and debt instruments. The regulations in this document provide guidance to brokers and payors and to their customers.
2016-02-11Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAdditional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014The Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have...2016-02772"https://www.gpo.gov/fdsys/pkg/FR-2016-02-11/pdf/2016-02772.pdfhttps://www.federalregister.gov/documents/2016/02/11/2016-02772/additional-limitation-on-suspension-of-benefits-applicable-to-certain-pension-plans-under-theThe Multiemployer Pension Reform Act of 2014 (``MPRA''), which was enacted by Congress as part of the Consolidated and Further Continuing Appropriations Act of 2015, relates to multiemployer defined benefit pension plans that are projected to have insufficient funds, within a specified timeframe, to pay the full plan benefits to which individuals will be entitled (referred to as plans in ``critical and declining status''). Under MPRA, the sponsor of such a plan is permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions and limitations are satisfied (referred to in MPRA as a ``suspension of benefits''). One specific limitation governs the application of a suspension of benefits under any plan that includes benefits directly attributable to a participant's service with any employer that has withdrawn from the plan in a complete withdrawal, paid its full withdrawal liability, and, pursuant to a collective bargaining agreement, assumed liability for providing benefits to participants and beneficiaries equal to any benefits for such participants and beneficiaries reduced as a result of the financial status of the plan. This document contains proposed regulations that would provide guidance relating to this specific limitation. These regulations affect active, retired, and deferred vested participants and beneficiaries under any such multiemployer plan in critical and declining status as well as employers contributing to, and sponsors and administrators of, those plans.
2016-02-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAllocation of Creditable Foreign TaxesThis document contains temporary regulations that provide guidance relating to the allocation by a partnership of creditable foreign tax expenditures. These temporary regulations are necessary to improve the operation of an existing safe harbor rule...2016-01949"https://www.gpo.gov/fdsys/pkg/FR-2016-02-04/pdf/2016-01949.pdfhttps://www.federalregister.gov/documents/2016/02/04/2016-01949/allocation-of-creditable-foreign-taxesThis document contains temporary regulations that provide guidance relating to the allocation by a partnership of creditable foreign tax expenditures. These temporary regulations are necessary to improve the operation of an existing safe harbor rule that is used for determining whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners' interests in the partnership. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking (REG-100861-15) published in the Proposed Rules section in this issue of the Federal Register. These regulations affect partnerships that pay or accrue foreign income taxes, and their partners.
2016-02-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAllocation of Creditable Foreign TaxesIn the Rules and Regulations section in this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to the allocation by a partnership of foreign income taxes. Those temporary regulations are necessary to...2016-01948"https://www.gpo.gov/fdsys/pkg/FR-2016-02-04/pdf/2016-01948.pdfhttps://www.federalregister.gov/documents/2016/02/04/2016-01948/allocation-of-creditable-foreign-taxesIn the Rules and Regulations section in this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to the allocation by a partnership of foreign income taxes. Those temporary regulations are necessary to improve the operation of an existing safe harbor rule that is used for determining whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners' interests in the partnership. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.
2016-02-01Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property of Foreign Corporations; Hearing CorrectionThis document corrects a notice of public hearing on proposed regulations that published in the Federal Register on January 20, 2016, at 81 FR 3069.2016-01807"https://www.gpo.gov/fdsys/pkg/FR-2016-02-01/pdf/2016-01807.pdfhttps://www.federalregister.gov/documents/2016/02/01/2016-01807/treatment-of-certain-transfers-of-property-of-foreign-corporations-hearing-correctionThis document corrects a notice of public hearing on proposed regulations that published in the Federal Register on January 20, 2016, at 81 FR 3069.
2016-01-29Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentNondiscrimination Relief for Closed Defined Benefit Pension Plans and Additional Changes to the Retirement Plan Nondiscrimination RequirementsThis document contains proposed regulations that modify the nondiscrimination requirements applicable to certain retirement plans that provide additional benefits to a grandfathered group of employees following certain changes in the coverage of a...2016-01675"https://www.gpo.gov/fdsys/pkg/FR-2016-01-29/pdf/2016-01675.pdfhttps://www.federalregister.gov/documents/2016/01/29/2016-01675/nondiscrimination-relief-for-closed-defined-benefit-pension-plans-and-additional-changes-to-theThis document contains proposed regulations that modify the nondiscrimination requirements applicable to certain retirement plans that provide additional benefits to a grandfathered group of employees following certain changes in the coverage of a defined benefit plan or a defined benefit plan formula. The proposed regulations also make certain other changes to the nondiscrimination rules that are not limited to these plans. These regulations would affect participants in, beneficiaries of, employers maintaining, and administrators of tax- qualified retirement plans.
2016-01-27Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisguised Payments for Services; HearingThis document provides a notice of public hearing on proposed regulations relating to disguised payments for services under section 707(a)(2)(A) of the Internal Revenue Code.2016-01520"https://www.gpo.gov/fdsys/pkg/FR-2016-01-27/pdf/2016-01520.pdfhttps://www.federalregister.gov/documents/2016/01/27/2016-01520/disguised-payments-for-services-hearingThis document provides a notice of public hearing on proposed regulations relating to disguised payments for services under section 707(a)(2)(A) of the Internal Revenue Code.
2016-01-27Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentApplicability of Normal Retirement Age Regulations to Governmental Pension PlansThis document contains proposed regulations under section 401(a) of the Internal Revenue Code (Code). These regulations would provide rules relating to the determination of whether the normal retirement age under a governmental plan (within the meaning...2016-01639"https://www.gpo.gov/fdsys/pkg/FR-2016-01-27/pdf/2016-01639.pdfhttps://www.federalregister.gov/documents/2016/01/27/2016-01639/applicability-of-normal-retirement-age-regulations-to-governmental-pension-plansThis document contains proposed regulations under section 401(a) of the Internal Revenue Code (Code). These regulations would provide rules relating to the determination of whether the normal retirement age under a governmental plan (within the meaning of section 414(d) of the Code) that is a pension plan satisfies the requirements of section 401(a) and whether the payment of definitely determinable benefits that commence at the plan's normal retirement age satisfies these requirements. These regulations would affect sponsors and administrators of governmental pension plans, as well as participants in such plans.
2016-01-26Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSpecial Enrollment Examination User Fee for Enrolled AgentsThis document contains proposed amendments to the regulation relating to the user fee for the special enrollment examination to become an enrolled agent. The charging of user fees is authorized by the Independent Offices Appropriations Act (IOAA) of...2016-01629"https://www.gpo.gov/fdsys/pkg/FR-2016-01-26/pdf/2016-01629.pdfhttps://www.federalregister.gov/documents/2016/01/26/2016-01629/special-enrollment-examination-user-fee-for-enrolled-agentsThis document contains proposed amendments to the regulation relating to the user fee for the special enrollment examination to become an enrolled agent. The charging of user fees is authorized by the Independent Offices Appropriations Act (IOAA) of 1952. This document also contains a notice of public hearing on this proposed regulation. The proposed regulation affects individuals taking the enrolled agent special enrollment examination.
2016-01-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property of Foreign Corporations; HearingThis document provides notice of public hearing on the proposed regulations relating to certain transfers of property by United States persons to foreign corporations. The proposed regulations affect United States persons that transfer certain...2016-00961"https://www.gpo.gov/fdsys/pkg/FR-2016-01-20/pdf/2016-00961.pdfhttps://www.federalregister.gov/documents/2016/01/20/2016-00961/treatment-of-certain-transfers-of-property-of-foreign-corporations-hearingThis document provides notice of public hearing on the proposed regulations relating to certain transfers of property by United States persons to foreign corporations. The proposed regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in non-recognition transactions described in section 367 of the Internal Revenue Code.
2016-01-15RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMinimum Value of Eligible Employer-Sponsored Plans and Other Rules Regarding the Health Insurance Premium Tax Credit; CorrectionThis document contains corrections to final regulations (TD 9745) that were published in the Federal Register on Friday, December 18, 2015 (80 FR 78971). The final regulations are on the health insurance premium tax credit enacted by the Patient...2016-00701"https://www.gpo.gov/fdsys/pkg/FR-2016-01-15/pdf/2016-00701.pdfhttps://www.federalregister.gov/documents/2016/01/15/2016-00701/minimum-value-of-eligible-employer-sponsored-plans-and-other-rules-regarding-the-health-insuranceThis document contains corrections to final regulations (TD 9745) that were published in the Federal Register on Friday, December 18, 2015 (80 FR 78971). The final regulations are on the health insurance premium tax credit enacted by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, as amended by the Medicare and Medicaid Extenders Act of 2010, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, and the Department of Defense and Full Year Continuing Appropriations Act, 2011.
2016-01-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRelief From Joint and Several Liability; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-134219-08) that was published in the Federal Register on Friday, November 20, 2015 (80 FR 72649). The proposed regulations are relating to relief from joint and several...2016-00430"https://www.gpo.gov/fdsys/pkg/FR-2016-01-13/pdf/2016-00430.pdfhttps://www.federalregister.gov/documents/2016/01/13/2016-00430/relief-from-joint-and-several-liability-correctionThis document contains corrections to a notice of proposed rulemaking (REG-134219-08) that was published in the Federal Register on Friday, November 20, 2015 (80 FR 72649). The proposed regulations are relating to relief from joint and several liability under section 6015 of the Internal Revenue Code.
2016-01-12Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinitions of Terms Relating to Marital Status; HearingThis document provides notice of public hearing on proposed regulations relating to the holdings of Obergefell v. Hodges, 2015, Windsor v. United States, 2013, and a revenue ruling that define terms in the Internal Revenue Code (Code) describing the...2016-00386"https://www.gpo.gov/fdsys/pkg/FR-2016-01-12/pdf/2016-00386.pdfhttps://www.federalregister.gov/documents/2016/01/12/2016-00386/definitions-of-terms-relating-to-marital-status-hearingThis document provides notice of public hearing on proposed regulations relating to the holdings of Obergefell v. Hodges, 2015, Windsor v. United States, 2013, and a revenue ruling that define terms in the Internal Revenue Code (Code) describing the marital status of taxpayers.
2016-01-08Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSubstantiation Requirement for Certain Contributions; WithdrawalThis document withdraws proposed regulations that would implement the statutory exception to the ``contemporaneous written acknowledgement'' requirement for substantiating charitable contribution deductions of $250 or more. The withdrawal affects...2016-00189"https://www.gpo.gov/fdsys/pkg/FR-2016-01-08/pdf/2016-00189.pdfhttps://www.federalregister.gov/documents/2016/01/08/2016-00189/substantiation-requirement-for-certain-contributions-withdrawalThis document withdraws proposed regulations that would implement the statutory exception to the ``contemporaneous written acknowledgement'' requirement for substantiating charitable contribution deductions of $250 or more. The withdrawal affects persons that make charitable contributions and organizations that receive charitable contributions.
2016-01-05Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United States; Hearing CancellationThis document cancels a public hearing on proposed regulations providing guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference...2015-33090"https://www.gpo.gov/fdsys/pkg/FR-2016-01-05/pdf/2015-33090.pdfhttps://www.federalregister.gov/documents/2016/01/05/2015-33090/dividend-equivalents-from-sources-within-the-united-states-hearing-cancellationThis document cancels a public hearing on proposed regulations providing guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.
2015-12-23Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentCountry-by-Country ReportingThis document contains proposed regulations that would require annual country-by-country reporting by United States persons (U.S. persons) that are the ultimate parent entity of a multinational enterprise (MNE) group. These proposed regulations affect...2015-32145"https://www.gpo.gov/fdsys/pkg/FR-2015-12-23/pdf/2015-32145.pdfhttps://www.federalregister.gov/documents/2015/12/23/2015-32145/country-by-country-reportingThis document contains proposed regulations that would require annual country-by-country reporting by United States persons (U.S. persons) that are the ultimate parent entity of a multinational enterprise (MNE) group. These proposed regulations affect U.S. persons that are the ultimate parent entity of an MNE group that has annual revenue for the preceding annual accounting period of $850,000,000 or more. This document invites comments from the public on all aspects of the proposed rules and provides the opportunity for the public to request a public hearing.
2015-12-23RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPayout Requirements for Type III Supporting Organizations That Are Not Functionally IntegratedThis document contains final regulations regarding the distribution requirement for non-functionally integrated Type III supporting organizations. The regulations reflect changes to the law made by the Pension Protection Act of 2006. The regulations...2015-32146"https://www.gpo.gov/fdsys/pkg/FR-2015-12-23/pdf/2015-32146.pdfhttps://www.federalregister.gov/documents/2015/12/23/2015-32146/payout-requirements-for-type-iii-supporting-organizations-that-are-not-functionally-integratedThis document contains final regulations regarding the distribution requirement for non-functionally integrated Type III supporting organizations. The regulations reflect changes to the law made by the Pension Protection Act of 2006. The regulations will affect non-functionally integrated Type III supporting organizations and their supported organizations.
2015-12-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentMinimum Value of Eligible Employer-Sponsored Plans and Other Rules Regarding the Health Insurance Premium Tax CreditThis document contains final regulations on the health insurance premium tax credit enacted by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, as amended by the Medicare and Medicaid...2015-31866"https://www.gpo.gov/fdsys/pkg/FR-2015-12-18/pdf/2015-31866.pdfhttps://www.federalregister.gov/documents/2015/12/18/2015-31866/minimum-value-of-eligible-employer-sponsored-plans-and-other-rules-regarding-the-health-insuranceThis document contains final regulations on the health insurance premium tax credit enacted by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, as amended by the Medicare and Medicaid Extenders Act of 2010, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, and the Department of Defense and Full-Year Continuing Appropriations Act, 2011. These final regulations affect individuals who enroll in qualified health plans through Affordable Insurance Exchanges (Exchanges, sometimes called Marketplaces) and claim the health insurance premium tax credit, and Exchanges that make qualified health plans available to individuals and employers.
2015-12-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReorganizations Under Section 368(a)(1)(F); Section 367(a) and Certain Reorganizations Under Section 368(a)(1)(F); CorrectionThis document contains corrections to final regulations (TD 9739) that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F), and which were published in the Federal Register on Monday,...2015-30869"https://www.gpo.gov/fdsys/pkg/FR-2015-12-08/pdf/2015-30869.pdfhttps://www.federalregister.gov/documents/2015/12/08/2015-30869/reorganizations-under-section-368a1f-section-367a-and-certain-reorganizations-under-section-368a1fThis document contains corrections to final regulations (TD 9739) that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F), and which were published in the Federal Register on Monday, September 21, 2015 (80 FR 56904).
2015-12-07Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United States; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-127894-14) that was published in the Federal Register on Friday, September 18, 2015 (80 FR 56415). The proposed regulations provide guidance relating to the substantial...2015-30779"https://www.gpo.gov/fdsys/pkg/FR-2015-12-07/pdf/2015-30779.pdfhttps://www.federalregister.gov/documents/2015/12/07/2015-30779/dividend-equivalents-from-sources-within-the-united-states-correctionThis document contains corrections to a notice of proposed rulemaking (REG-127894-14) that was published in the Federal Register on Friday, September 18, 2015 (80 FR 56415). The proposed regulations provide guidance relating to the substantial equivalence test, which is used to determine whether a complex contract is a section 871(m) transaction.
2015-12-07RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United States; CorrectionThis document contains corrections to final and temporary regulations (TD 9734) that was published in the Federal Register on September 18, 2015 (80 FR 56866). These corrections include a change to the effective date that was applicable to transactions...2015-30777"https://www.gpo.gov/fdsys/pkg/FR-2015-12-07/pdf/2015-30777.pdfhttps://www.federalregister.gov/documents/2015/12/07/2015-30777/dividend-equivalents-from-sources-within-the-united-states-correctionThis document contains corrections to final and temporary regulations (TD 9734) that was published in the Federal Register on September 18, 2015 (80 FR 56866). These corrections include a change to the effective date that was applicable to transactions issued on or after January 1, 2016, and before January 1, 2017. This document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.
2015-12-07RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United States; CorrectionThis document contains corrections to final and temporary regulations (TD 9734) that was published in the Federal Register on September 18, 2015 (80 FR 56866). These corrections include a change to the effective date that was applicable to transactions...2015-30778"https://www.gpo.gov/fdsys/pkg/FR-2015-12-07/pdf/2015-30778.pdfhttps://www.federalregister.gov/documents/2015/12/07/2015-30778/dividend-equivalents-from-sources-within-the-united-states-correctionThis document contains corrections to final and temporary regulations (TD 9734) that was published in the Federal Register on September 18, 2015 (80 FR 56866). These corrections include a change to the effective date that was applicable to transactions issued on or after January 1, 2016, and before January 1, 2017. This document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.
2015-11-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGeneral Allocation and Accounting Regulations Under Section 141; Remedial Actions for Tax-Exempt Bonds; CorrectionThis document contains corrections to final regulations (TD 9741) that were published in the Federal Register on Tuesday, October 27, 2015 (80 FR 65637). The final regulations on allocation and accounting, and certain remedial actions, for purposes of...2015-30321"https://www.gpo.gov/fdsys/pkg/FR-2015-11-30/pdf/2015-30321.pdfhttps://www.federalregister.gov/documents/2015/11/30/2015-30321/general-allocation-and-accounting-regulations-under-section-141-remedial-actions-for-tax-exemptThis document contains corrections to final regulations (TD 9741) that were published in the Federal Register on Tuesday, October 27, 2015 (80 FR 65637). The final regulations on allocation and accounting, and certain remedial actions, for purposes of the private activity bond restrictions under section 141of the Internal Revenue Code that apply to tax-exempt bonds issued by State and local governments.
2015-11-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGeneral Allocation and Accounting Regulations Under Section 141; Remedial Actions for Tax-Exempt Bonds; CorrectionThis document contains corrections to final regulations (TD 9741) that were published in the Federal Register on Tuesday, October 27, 2015 (80 FR 65637). The final regulations provide guidance on allocation and accounting, and certain remedial actions,...2015-30322"https://www.gpo.gov/fdsys/pkg/FR-2015-11-30/pdf/2015-30322.pdfhttps://www.federalregister.gov/documents/2015/11/30/2015-30322/general-allocation-and-accounting-regulations-under-section-141-remedial-actions-for-tax-exemptThis document contains corrections to final regulations (TD 9741) that were published in the Federal Register on Tuesday, October 27, 2015 (80 FR 65637). The final regulations provide guidance on allocation and accounting, and certain remedial actions, for purposes of the private activity bond restrictions under section 141of the Internal Revenue Code that apply to tax-exempt bonds issued by State and local governments.
2015-11-20Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentRelief From Joint and Several LiabilityThis document contains proposed regulations relating to relief from joint and several liability under section 6015 of the Internal Revenue Code (Code). The regulations reflect changes in the law made by the Tax Relief and Health Care Act of 2006 as...2015-29609"https://www.gpo.gov/fdsys/pkg/FR-2015-11-20/pdf/2015-29609.pdfhttps://www.federalregister.gov/documents/2015/11/20/2015-29609/relief-from-joint-and-several-liabilityThis document contains proposed regulations relating to relief from joint and several liability under section 6015 of the Internal Revenue Code (Code). The regulations reflect changes in the law made by the Tax Relief and Health Care Act of 2006 as well as changes in the law arising from litigation. The regulations provide guidance to married individuals who filed joint returns and later seek relief from joint and several liability.
2015-11-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentFinal Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protections Under the Affordable Care ActThis document contains final regulations regarding grandfathered health plans, preexisting condition exclusions, lifetime and annual dollar limits on benefits, rescissions, coverage of dependent children to age 26, internal claims and appeal and...2015-29294"https://www.gpo.gov/fdsys/pkg/FR-2015-11-18/pdf/2015-29294.pdfhttps://www.federalregister.gov/documents/2015/11/18/2015-29294/final-rules-for-grandfathered-plans-preexisting-condition-exclusions-lifetime-and-annual-limitsThis document contains final regulations regarding grandfathered health plans, preexisting condition exclusions, lifetime and annual dollar limits on benefits, rescissions, coverage of dependent children to age 26, internal claims and appeal and external review processes, and patient protections under the Affordable Care Act. It finalizes changes to the proposed and interim final rules based on comments and incorporates subregulatory guidance issued since publication of the proposed and interim final rules.
2015-11-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAdministration of Multiemployer Plan Participant Vote on an Approved Suspension of Benefits Under MPRA; HearingThis document provides notice of public hearing on proposed regulations relating to the administration of a multiemployer plan participant vote on an approved suspension of benefits under the Multiemployer Pension Reform Act of 2014 (MPRA) that were...2015-29289"https://www.gpo.gov/fdsys/pkg/FR-2015-11-17/pdf/2015-29289.pdfhttps://www.federalregister.gov/documents/2015/11/17/2015-29289/administration-of-multiemployer-plan-participant-vote-on-an-approved-suspension-of-benefits-underThis document provides notice of public hearing on proposed regulations relating to the administration of a multiemployer plan participant vote on an approved suspension of benefits under the Multiemployer Pension Reform Act of 2014 (MPRA) that were issued in the Proposed Rules section of the Federal Register on September 2, 2015.
2015-11-16RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTransitional Amendments To Satisfy the Market Rate of Return Rules for Hybrid Retirement PlansThis document contains final regulations that provide guidance regarding certain amendments to applicable defined benefit plans. Applicable defined benefit plans are defined benefit plans that use a lump sum-based benefit formula, including cash...2015-28915"https://www.gpo.gov/fdsys/pkg/FR-2015-11-16/pdf/2015-28915.pdfhttps://www.federalregister.gov/documents/2015/11/16/2015-28915/transitional-amendments-to-satisfy-the-market-rate-of-return-rules-for-hybrid-retirement-plansThis document contains final regulations that provide guidance regarding certain amendments to applicable defined benefit plans. Applicable defined benefit plans are defined benefit plans that use a lump sum-based benefit formula, including cash balance plans and pension equity plans, as well as other plans that have formulas with an effect similar to a lump sum-based benefit formula. These final regulations relate to previously issued final regulations that specify permitted interest crediting rates for purposes of the requirement that an applicable defined benefit plan not provide for interest credits (or equivalent amounts) at an effective rate that is greater than a market rate of return. These final regulations permit a plan sponsor of an applicable defined benefit plan that does not comply with the market rate of return requirement to amend the plan in order to change to an interest crediting rate that is permitted under the previously issued final hybrid plan regulations without violating the anti-cutback rules of section 411(d)(6). These regulations affect sponsors, administrators, participants, and beneficiaries of these plans.
2015-11-06Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentExtension of Time To File Certain Information Returns; Extension of Comment PeriodThis document extends the comment period for a notice of proposed rulemaking (REG-132075-14) that was published in the Federal Register on Thursday, August 13, 2015. The proposed regulations relate to extensions of time to file information returns on...2015-28279"https://www.gpo.gov/fdsys/pkg/FR-2015-11-06/pdf/2015-28279.pdfhttps://www.federalregister.gov/documents/2015/11/06/2015-28279/extension-of-time-to-file-certain-information-returns-extension-of-comment-periodThis document extends the comment period for a notice of proposed rulemaking (REG-132075-14) that was published in the Federal Register on Thursday, August 13, 2015. The proposed regulations relate to extensions of time to file information returns on forms in the W-2 series (except Form W-2G).
2015-11-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDetermination of Distributive Share When Partner's Interest Changes; CorrectionThis document contains corrections to final regulations (TD 9728) that were published in the Federal Register on Monday, August 3, 2015 (80 FR 45865). The final regulations regarding the determination of a partner's distributive share of partnership...2015-28014"https://www.gpo.gov/fdsys/pkg/FR-2015-11-04/pdf/2015-28014.pdfhttps://www.federalregister.gov/documents/2015/11/04/2015-28014/determination-of-distributive-share-when-partners-interest-changes-correctionThis document contains corrections to final regulations (TD 9728) that were published in the Federal Register on Monday, August 3, 2015 (80 FR 45865). The final regulations regarding the determination of a partner's distributive share of partnership items of income, gain, loss, deduction, and credit when a partner's interest varies during a partnership taxable year.
2015-11-04Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property to Foreign Corporations; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-139483-13) that was published in the Federal Register on Wednesday, September 16, 2015 (80 FR 55568). The proposed regulations are relating to certain transfers of property by...2015-28013"https://www.gpo.gov/fdsys/pkg/FR-2015-11-04/pdf/2015-28013.pdfhttps://www.federalregister.gov/documents/2015/11/04/2015-28013/treatment-of-certain-transfers-of-property-to-foreign-corporations-correctionThis document contains corrections to a notice of proposed rulemaking (REG-139483-13) that was published in the Federal Register on Wednesday, September 16, 2015 (80 FR 55568). The proposed regulations are relating to certain transfers of property by United States persons to foreign corporations.
2015-11-04RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDetermination of Distributive Share When Partner's Interest Changes; CorrectionThis document contains corrections to final regulations (TD 9728) that were published in the Federal Register on Monday, August 3, 2015 (80 FR 45865). The final regulations are regarding the determination of a partner's distributive share of...2015-28015"https://www.gpo.gov/fdsys/pkg/FR-2015-11-04/pdf/2015-28015.pdfhttps://www.federalregister.gov/documents/2015/11/04/2015-28015/determination-of-distributive-share-when-partners-interest-changes-correctionThis document contains corrections to final regulations (TD 9728) that were published in the Federal Register on Monday, August 3, 2015 (80 FR 45865). The final regulations are regarding the determination of a partner's distributive share of partnership items of income, gain, loss, deduction, and credit when a partner's interest varies during a partnership taxable year.
2015-10-30RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPreparer Tax Identification Number (PTIN) User Fee UpdateThis document contains temporary regulations relating to the imposition of certain user fees on tax return preparers. The temporary regulations reduce the user fee to apply for or renew a preparer tax identification number (PTIN) and affect individuals...2015-27789"https://www.gpo.gov/fdsys/pkg/FR-2015-10-30/pdf/2015-27789.pdfhttps://www.federalregister.gov/documents/2015/10/30/2015-27789/preparer-tax-identification-number-ptin-user-fee-updateThis document contains temporary regulations relating to the imposition of certain user fees on tax return preparers. The temporary regulations reduce the user fee to apply for or renew a preparer tax identification number (PTIN) and affect individuals who apply for or renew a PTIN. The Independent Offices Appropriations Act of 1952 authorizes the charging of user fees. The text of the temporary regulations also serves as the text of the proposed regulations (REG- 121496-15) set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
2015-10-30Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentPreparer Tax Identification Number (PTIN) User Fee UpdateIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that will amend regulations (TD 9503) relating to the imposition of certain user fees on tax return preparers. The temporary...2015-27791"https://www.gpo.gov/fdsys/pkg/FR-2015-10-30/pdf/2015-27791.pdfhttps://www.federalregister.gov/documents/2015/10/30/2015-27791/preparer-tax-identification-number-ptin-user-fee-updateIn the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that will amend regulations (TD 9503) relating to the imposition of certain user fees on tax return preparers. The temporary regulations reduce the amount of the user fee to apply for or renew a preparer tax identification number (PTIN). The text of the temporary regulations also serves as the text of these proposed regulations.
2015-10-29Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-155164-09) that was published in the Federal Register on Wednesday, September 2, 2015 (80 FR 53058). The proposed rules are regarding the treatment as United States property of...2015-27601"https://www.gpo.gov/fdsys/pkg/FR-2015-10-29/pdf/2015-27601.pdfhttps://www.federalregister.gov/documents/2015/10/29/2015-27601/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains corrections to a notice of proposed rulemaking (REG-155164-09) that was published in the Federal Register on Wednesday, September 2, 2015 (80 FR 53058). The proposed rules are regarding the treatment as United States property of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.
2015-10-29RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; CorrectionThis document contains corrections to final and temporary regulations (TD 9733) that were published in the Federal Register on September 2, 2015 (80 FR 52976). The temporary regulations are regarding the treatment as United States property of property...2015-27603"https://www.gpo.gov/fdsys/pkg/FR-2015-10-29/pdf/2015-27603.pdfhttps://www.federalregister.gov/documents/2015/10/29/2015-27603/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains corrections to final and temporary regulations (TD 9733) that were published in the Federal Register on September 2, 2015 (80 FR 52976). The temporary regulations are regarding the treatment as United States property of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.
2015-10-29Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentAllocable Cash Basis and Tiered Partnership Items; CorrectionThis document contains corrections to a notice of proposed rulemaking (REG-109370-10) that was published in the Federal Register on Monday, August 3, 2015 (80 FR 45905). The proposed regulations are regarding the determination of a partner's...2015-27609"https://www.gpo.gov/fdsys/pkg/FR-2015-10-29/pdf/2015-27609.pdfhttps://www.federalregister.gov/documents/2015/10/29/2015-27609/allocable-cash-basis-and-tiered-partnership-items-correctionThis document contains corrections to a notice of proposed rulemaking (REG-109370-10) that was published in the Federal Register on Monday, August 3, 2015 (80 FR 45905). The proposed regulations are regarding the determination of a partner's distributive share of certain allocable cash basis items and items attributable to an interest in a lower-tier partnership during a partnership taxable year in which a partner's interest changes.
2015-10-29RuleDEPARTMENT OF THE TREASURYTreasury DepartmentUnited States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; CorrectionThis document contains corrections to final and temporary regulations (TD 9733) that were published in the Federal Register on September 2, 2015 (80 FR 52976). The temporary regulations are regarding the treatment as United States property of property...2015-27604"https://www.gpo.gov/fdsys/pkg/FR-2015-10-29/pdf/2015-27604.pdfhttps://www.federalregister.gov/documents/2015/10/29/2015-27604/united-states-property-held-by-controlled-foreign-corporations-in-transactions-involvingThis document contains corrections to final and temporary regulations (TD 9733) that were published in the Federal Register on September 2, 2015 (80 FR 52976). The temporary regulations are regarding the treatment as United States property of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.
2015-10-27Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGeneral Allocation and Accounting Regulations Under Section 141This document withdraws a portion of the notice of proposed rulemaking published in the Federal Register on September 26, 2006 (71 FR 56072). The withdrawn portion relates to certain general definitions for purposes of section 141 of the Internal...2015-27319"https://www.gpo.gov/fdsys/pkg/FR-2015-10-27/pdf/2015-27319.pdfhttps://www.federalregister.gov/documents/2015/10/27/2015-27319/general-allocation-and-accounting-regulations-under-section-141This document withdraws a portion of the notice of proposed rulemaking published in the Federal Register on September 26, 2006 (71 FR 56072). The withdrawn portion relates to certain general definitions for purposes of section 141 of the Internal Revenue Code and the treatment of partnerships for purposes of section 145(a).
2015-10-27RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGeneral Allocation and Accounting Regulations Under Section 141; Remedial Actions for Tax-Exempt BondsThis document contains final regulations on allocation and accounting, and certain remedial actions, for purposes of the private activity bond restrictions under section 141 of the Internal Revenue Code that apply to tax-exempt bonds issued by State...2015-27328"https://www.gpo.gov/fdsys/pkg/FR-2015-10-27/pdf/2015-27328.pdfhttps://www.federalregister.gov/documents/2015/10/27/2015-27328/general-allocation-and-accounting-regulations-under-section-141-remedial-actions-for-tax-exemptThis document contains final regulations on allocation and accounting, and certain remedial actions, for purposes of the private activity bond restrictions under section 141 of the Internal Revenue Code that apply to tax-exempt bonds issued by State and local governments. The final regulations provide State and local governmental issuers of tax-exempt bonds with guidance for applying the private activity bond restrictions.
2015-10-23Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDefinition of Terms Relating to Marital StatusThis document contains proposed regulations that reflect the holdings of Obergefell v. Hodges, 576 U.S. __, 135 S. Ct. 2584 (2015), Windsor v. United States, 570 U.S. __, 133 S. Ct. 2675 (2013), and Revenue Ruling 2013-17 (2013-38 IRB 201), and that...2015-26890"https://www.gpo.gov/fdsys/pkg/FR-2015-10-23/pdf/2015-26890.pdfhttps://www.federalregister.gov/documents/2015/10/23/2015-26890/definition-of-terms-relating-to-marital-statusThis document contains proposed regulations that reflect the holdings of Obergefell v. Hodges, 576 U.S. __, 135 S. Ct. 2584 (2015), Windsor v. United States, 570 U.S. __, 133 S. Ct. 2675 (2013), and Revenue Ruling 2013-17 (2013-38 IRB 201), and that define terms in the Internal Revenue Code (Code) describing the marital status of taxpayers. The proposed regulations primarily affect married couples, employers, sponsors and administrators of employee benefit plans, and executors. This document invites comments from the public regarding these proposed regulations.
2015-10-13Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDisguised Payments for Services; Extension of Comment PeriodThis document extends the comment period for a notice of proposed rulemaking (REG-115452-14) that was published in the Federal Register on Thursday, July 23, 2015. The proposed regulations relate to disguised payments for services under section...2015-25940"https://www.gpo.gov/fdsys/pkg/FR-2015-10-13/pdf/2015-25940.pdfhttps://www.federalregister.gov/documents/2015/10/13/2015-25940/disguised-payments-for-services-extension-of-comment-periodThis document extends the comment period for a notice of proposed rulemaking (REG-115452-14) that was published in the Federal Register on Thursday, July 23, 2015. The proposed regulations relate to disguised payments for services under section 707(a)(2)(A) of the Internal Revenue Code.
2015-10-13RuleDEPARTMENT OF THE TREASURYTreasury DepartmentNotional Principal Contracts; Swaps With Nonperiodic PaymentsThis document contains amendments to temporary regulations relating to guidance for the treatment of nonperiodic payments made or received pursuant to certain notional principal contracts. These amendments change the applicability date of the embedded...2015-25921"https://www.gpo.gov/fdsys/pkg/FR-2015-10-13/pdf/2015-25921.pdfhttps://www.federalregister.gov/documents/2015/10/13/2015-25921/notional-principal-contracts-swaps-with-nonperiodic-paymentsThis document contains amendments to temporary regulations relating to guidance for the treatment of nonperiodic payments made or received pursuant to certain notional principal contracts. These amendments change the applicability date of the embedded loan rule for the treatment of nonperiodic payments from November 4, 2015, to the later of January 1, 2017, or six months after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register. The amendments to the temporary regulations provide guidance to taxpayers who are parties making and receiving nonperiodic payments under notional principal contracts.
2015-10-06RuleDEPARTMENT OF THE TREASURYTreasury DepartmentControlled Group Regulation Examples; CorrectionThis document contains corrections to final regulations (TD 9737) that were published in the Federal Register on Tuesday, September 15, 2015 (80 FR 55243). The final rules are with revisions to examples that illustrate the controlled group rules...2015-25355"https://www.gpo.gov/fdsys/pkg/FR-2015-10-06/pdf/2015-25355.pdfhttps://www.federalregister.gov/documents/2015/10/06/2015-25355/controlled-group-regulation-examples-correctionThis document contains corrections to final regulations (TD 9737) that were published in the Federal Register on Tuesday, September 15, 2015 (80 FR 55243). The final rules are with revisions to examples that illustrate the controlled group rules applicable to regulated investment companies (RICs).
2015-09-28Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentQualifying Income From Activities of Publicly Traded Partnerships With Respect to Minerals or Natural Resources; HearingThis document provides notice of public hearing on proposed regulations relates to section 7704(d)(1)(E) of the Internal Revenue Code relating to qualifying income from exploration, development, mining or production, processing, refining,...2015-24568"https://www.gpo.gov/fdsys/pkg/FR-2015-09-28/pdf/2015-24568.pdfhttps://www.federalregister.gov/documents/2015/09/28/2015-24568/qualifying-income-from-activities-of-publicly-traded-partnerships-with-respect-to-minerals-orThis document provides notice of public hearing on proposed regulations relates to section 7704(d)(1)(E) of the Internal Revenue Code relating to qualifying income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or production, processing, refining, transportation, and marketing of minerals or natural resources.
2015-09-25RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReliance Standards for Making Good Faith DeterminationsThis document contains final regulations regarding the standards for making a good faith determination that a foreign organization is a charitable organization that is not a private foundation, so that grants made to that foreign organization may be...2015-24346"https://www.gpo.gov/fdsys/pkg/FR-2015-09-25/pdf/2015-24346.pdfhttps://www.federalregister.gov/documents/2015/09/25/2015-24346/reliance-standards-for-making-good-faith-determinationsThis document contains final regulations regarding the standards for making a good faith determination that a foreign organization is a charitable organization that is not a private foundation, so that grants made to that foreign organization may be qualifying distributions and not taxable expenditures. The regulations also make additional changes to conform the final regulations to statutory amendments made by the Deficit Reduction Act of 1984 and the Pension Protection Act of 2006. The regulations will affect private foundations seeking to make good faith determinations.
2015-09-21RuleDEPARTMENT OF THE TREASURYTreasury DepartmentReorganizations Under Section 368(a)(1)(F); Section 367(a) and Certain Reorganizations Under Section 368(a)(1)(F)This document contains final regulations that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F) by virtue of being a mere change of identity, form, or place of organization of one...2015-23603"https://www.gpo.gov/fdsys/pkg/FR-2015-09-21/pdf/2015-23603.pdfhttps://www.federalregister.gov/documents/2015/09/21/2015-23603/reorganizations-under-section-368a1f-section-367a-and-certain-reorganizations-under-section-368a1fThis document contains final regulations that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F) by virtue of being a mere change of identity, form, or place of organization of one corporation (F reorganization). This document also contains final regulations relating to F reorganizations in which the transferor corporation is a domestic corporation and the acquiring corporation is a foreign corporation (an outbound F reorganization). These regulations will affect corporations engaging in transactions that could qualify as F reorganizations (including outbound F reorganizations) and their shareholders.
2015-09-18Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United StatesDATES: Written or electronic comments must be received by December 17, 2015. Outlines of topics to be discussed at the public hearing scheduled for January 15, 2016, at 10 a.m. must be received by December 17, 2015.2015-21753"https://www.gpo.gov/fdsys/pkg/FR-2015-09-18/pdf/2015-21753.pdfhttps://www.federalregister.gov/documents/2015/09/18/2015-21753/dividend-equivalents-from-sources-within-the-united-statesDATES: Written or electronic comments must be received by December 17, 2015. Outlines of topics to be discussed at the public hearing scheduled for January 15, 2016, at 10 a.m. must be received by December 17, 2015.
2015-09-18RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDividend Equivalents From Sources Within the United StatesThis document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments. This document...2015-21759"https://www.gpo.gov/fdsys/pkg/FR-2015-09-18/pdf/2015-21759.pdfhttps://www.federalregister.gov/documents/2015/09/18/2015-21759/dividend-equivalents-from-sources-within-the-united-statesThis document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments. This document also provides guidance to withholding agents that are responsible for withholding U.S. tax with respect to a dividend equivalent.
2015-09-17Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentSubstantiation Requirement for Certain ContributionsThis document contains proposed regulations to implement the exception to the ``contemporaneous written acknowledgement'' requirement for substantiating charitable contribution deductions of $250 or more. These proposed regulations provide rules...2015-23291"https://www.gpo.gov/fdsys/pkg/FR-2015-09-17/pdf/2015-23291.pdfhttps://www.federalregister.gov/documents/2015/09/17/2015-23291/substantiation-requirement-for-certain-contributionsThis document contains proposed regulations to implement the exception to the ``contemporaneous written acknowledgement'' requirement for substantiating charitable contribution deductions of $250 or more. These proposed regulations provide rules concerning the time and manner for donee organizations to file information returns that report the required information about contributions (donee reporting).
2015-09-16RuleDEPARTMENT OF THE TREASURYTreasury DepartmentClarification of the Coordination of the Transfer Pricing Rules With Other Code ProvisionsThis document contains temporary regulations that clarify the coordination of the application of the arm's length standard and the best method rule under section 482 of the Internal Revenue Code (Code) in conjunction with other provisions of the Code....2015-23278"https://www.gpo.gov/fdsys/pkg/FR-2015-09-16/pdf/2015-23278.pdfhttps://www.federalregister.gov/documents/2015/09/16/2015-23278/clarification-of-the-coordination-of-the-transfer-pricing-rules-with-other-code-provisionsThis document contains temporary regulations that clarify the coordination of the application of the arm's length standard and the best method rule under section 482 of the Internal Revenue Code (Code) in conjunction with other provisions of the Code. The text of the temporary regulations also serves in part as the text of the proposed regulations (REG-139483-13) published in the Proposed Rules section of this issue of the Federal Register. This document also contains final regulations that add cross-references in the existing final regulations under section 482 to relevant sections of these temporary regulations.
2015-09-16Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentTreatment of Certain Transfers of Property to Foreign CorporationsThis document contains proposed regulations relating to certain transfers of property by United States persons to foreign corporations. The proposed regulations affect United States persons that transfer certain property, including foreign goodwill and...2015-23279"https://www.gpo.gov/fdsys/pkg/FR-2015-09-16/pdf/2015-23279.pdfhttps://www.federalregister.gov/documents/2015/09/16/2015-23279/treatment-of-certain-transfers-of-property-to-foreign-corporationsThis document contains proposed regulations relating to certain transfers of property by United States persons to foreign corporations. The proposed regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The proposed regulations also combine portions of the existing regulations under section 367(a) into a single regulation. In addition, in the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under section 482 to clarify the coordination of the transfer pricing rules with other Code provisions. The text of those temporary regulations serves as the text of a portion of these proposed regulations.
2015-09-16RuleDEPARTMENT OF THE TREASURYTreasury DepartmentBasis in Interests in Tax-Exempt TrustsC1-2015-19846"https://www.gpo.gov/fdsys/pkg/FR-2015-09-16/pdf/C1-2015-19846.pdfhttps://www.federalregister.gov/documents/2015/09/16/C1-2015-19846/basis-in-interests-in-tax-exempt-trusts
2015-09-15RuleDEPARTMENT OF THE TREASURYTreasury DepartmentControlled Group Regulation ExamplesThis document contains final rules with revisions to examples that illustrate the controlled group rules applicable to regulated investment companies (RICs). The revised examples illustrate how the controlled group rules affect the RIC asset...2015-23137"https://www.gpo.gov/fdsys/pkg/FR-2015-09-15/pdf/2015-23137.pdfhttps://www.federalregister.gov/documents/2015/09/15/2015-23137/controlled-group-regulation-examplesThis document contains final rules with revisions to examples that illustrate the controlled group rules applicable to regulated investment companies (RICs). The revised examples illustrate how the controlled group rules affect the RIC asset diversification tests.
2015-09-10Proposed RuleDEPARTMENT OF THE TREASURYTreasury DepartmentGuidance Under Section 2801 Regarding the Imposition of Tax on Certain Gifts and Bequests From Covered ExpatriatesThis document contains proposed regulations relating to a tax on United States citizens and residents who receive gifts or bequests from certain individuals who relinquished United States citizenship or ceased to be lawful permanent residents of the...2015-22574"https://www.gpo.gov/fdsys/pkg/FR-2015-09-10/pdf/2015-22574.pdfhttps://www.federalregister.gov/documents/2015/09/10/2015-22574/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-fromThis document contains proposed regulations relating to a tax on United States citizens and residents who receive gifts or bequests from certain individuals who relinquished United States citizenship or ceased to be lawful permanent residents of the United States on or after June 17, 2008. These proposed regulations affect taxpayers who receive covered gifts or covered bequests on or after the date these regulations are published as final regulations in the Federal Register. This document also provides notice of a public hearing on these proposed regulations.
2015-09-09RuleDEPARTMENT OF THE TREASURYTreasury DepartmentDetermination of Minimum Required Pension ContributionsThis document contains final regulations providing guidance on the determination of minimum required contributions for single-employer defined benefit pension plans. In addition, this document contains final regulations regarding the excise tax for...2015-20914"https://www.gpo.gov/fdsys/pkg/FR-2015-09-09/pdf/2015-20914.pdfhttps://www.federalregister.gov/documents/2015/09/09/2015-20914/determination-of-minimum-required-pension-contributionsThis document contains final regulations providing guidance on the determination of minimum required contributions for single-employer defined benefit pension plans. In addition, this document contains final regulations regarding the excise tax for failure to satisfy the minimum funding requirements for defined benefit pension plans. These regulations affect sponsors, administrators, participants, and beneficiaries of defined benefit pension plans.
2015-09-08RuleDEPARTMENT OF THE TREASURYTreasury DepartmentIntegrated Hedging Transactions of Qualifying DebtThis document contains final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations provide that if a taxpayer has identified...2015-22554"https://www.gpo.gov/fdsys/pkg/FR-2015-09-08/pdf/2015-22554.pdfhttps://www.federalregister.gov/documents/2015/09/08/2015-22554/integrated-hedging-transactions-of-qualifying-debtThis document contains final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations provide that if a taxpayer has identified multiple hedges as being part of a qualified hedging transaction, and the taxpayer has terminated at least one but less than all of the hedges (including a portion of one or more of the hedges), the taxpayer must treat the remaining hedges as having been sold for fair market value on the date of disposition of the terminated hedge.
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