Department of Treasury April 8, 2016 – Federal Register Recent Federal Regulation Documents

Open Meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee
Document Number: 2016-08232
Type: Notice
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee
Document Number: 2016-08230
Type: Notice
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Treatment of Certain Interests in Corporations as Stock or Indebtedness
Document Number: 2016-07425
Type: Proposed Rule
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Inversions and Related Transactions
Document Number: 2016-07300
Type: Rule
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Inversions and Related Transactions
Document Number: 2016-07299
Type: Proposed Rule
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The 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.
Partial 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 Ownership
Document Number: 2016-07295
Type: Proposed Rule
Date: 2016-04-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.