Internal Revenue Service June 2016 – Federal Register Recent Federal Regulation Documents

Country-by-Country Reporting
Document Number: 2016-15482
Type: Rule
Date: 2016-06-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
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. 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.
Proposed Collection; Comment Request for Forms 8288 and 8288-A
Document Number: 2016-15459
Type: Notice
Date: 2016-06-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8288, U.S. Withholding Tax Return for Disposition by Foreign Persons of U.S. Real Property Interests, and Form 8288-A, Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests.
Proposed Collection; Comment Request for Form 6478
Document Number: 2016-15453
Type: Notice
Date: 2016-06-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 6478, Biofuel Producer Credit.
Art Advisory Panel-Notice of Availability of Report of 2015 Closed Meetings
Document Number: 2016-15452
Type: Notice
Date: 2016-06-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Pursuant to 5 U.S.C. App. 2, section 10(d), of the Federal Advisory Committee Act, and 5 U.S.C. 552b, of the Government in the Sunshine Act, a report summarizing the closed meeting activities of the Art Advisory Panel during Fiscal Year 2015 has been prepared. A copy of this report has been filed with the Assistant Secretary for Management of the Department of the Treasury.
Proposed Collection; Comment Request for e-Services Registration TIN Matching-Application and Screens for TIN Matching Interactive
Document Number: 2016-15434
Type: Notice
Date: 2016-06-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning e- Services registration TIN matchingapplication and screens for TIN matching interactive.
Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]; Correction
Document Number: 2016-15264
Type: Rule
Date: 2016-06-28
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Inversions and Related Transactions; Correction
Document Number: 2016-14649
Type: Rule
Date: 2016-06-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Inversions and Related Transactions; Correction
Document Number: 2016-14648
Type: Rule
Date: 2016-06-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Modification of Treatment of Certain Health Organizations
Document Number: 2016-14784
Type: Rule
Date: 2016-06-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Application of Section 409A to Nonqualified Deferred Compensation Plans
Document Number: 2016-14331
Type: Proposed Rule
Date: 2016-06-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Deferred Compensation Plans of State and Local Governments and Tax-Exempt Entities
Document Number: 2016-14329
Type: Proposed Rule
Date: 2016-06-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Treatment of a Certain Interests in Corporations as Stock or Indebtedness; Hearing
Document Number: 2016-14734
Type: Proposed Rule
Date: 2016-06-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2016-14109
Type: Notice
Date: 2016-06-15
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning information collect requirements related to the treatment of distributions to foreign persons under sections 367(e)(1) and 367(e)(2).
Proposed Information Collection; Comment Request
Document Number: 2016-14108
Type: Notice
Date: 2016-06-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)).
Consistent Basis Reporting Between Estate and Person Acquiring Property From Decedent; Hearing
Document Number: 2016-14010
Type: Proposed Rule
Date: 2016-06-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Guidance Under Section 108(a) Concerning the Exclusion of Section 61(a)(12) Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity
Document Number: 2016-13779
Type: Rule
Date: 2016-06-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Proposed Collection; Comment Request for Form 1099-H
Document Number: 2016-13778
Type: Notice
Date: 2016-06-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13(44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 1099-H, Health Coverage Tax Credit (HCTC) Advance Payments.
Expatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance
Document Number: 2016-13583
Type: Proposed Rule
Date: 2016-06-10
Agency: Employee Benefits Security Administration, Department of Labor, Department of Health and Human Services, Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]; Final and Temporary Regulations
Document Number: 2016-13443
Type: Rule
Date: 2016-06-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]
Document Number: 2016-13425
Type: Proposed Rule
Date: 2016-06-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
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 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.
Proposed Collection; Comment Request for Revenue Procedure 2016-29.
Document Number: 2016-13435
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13(44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2016-29, Changes in accounting periods and methods of accounting.
Open Meeting of the Taxpayer Advocacy Panel Special Projects Committee
Document Number: 2016-13434
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Special Projects 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 Taxpayer Assistance Center Improvements Project Committee
Document Number: 2016-13433
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Taxpayer Advocacy Panel Taxpayer Assistance Center Improvements Project Committee will conduct an open meeting and will solicit public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Joint Committee
Document Number: 2016-13432
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Joint 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: 2016-13431
Type: Notice
Date: 2016-06-07
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 Taxpayer Communications Project Committee
Document Number: 2016-13420
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Taxpayer Communications 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 Notices and Correspondence Project Committee
Document Number: 2016-13419
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Notices and Correspondence 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 Toll-Free Phone Line Project Committee.
Document Number: 2016-13418
Type: Notice
Date: 2016-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Toll-Free Phone Line 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.
Proposed Collection; Comment Request for Form 5578
Document Number: 2016-13094
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 5578, Annual Certification of Racial Nondiscrimination for a Private School Exempt From Federal Income Tax.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2016-13093
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning TD 8786, Source of Income From Sales of Inventory Partly From Sources Within a Possession of the United States; Also, Source of Income Derived From Certain Purchases From a Corporation Electing Section 936.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2016-13092
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning TD 9633, Limitations on Duplication of Net Built-in Losses.
Proposed Collection; Comment Request for Revenue Procedure 2000-42
Document Number: 2016-13091
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2000-42, Section 1503(d) Closing Agreement Requests.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2016-13090
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning netting rule for certain conversion transactions.
Proposed Collection; Comment Request for Revenue Procedure 2010-13
Document Number: 2016-13000
Type: Notice
Date: 2016-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2010-13, Section 469 Grouping activities.
Inversions and Related Transactions; Correction
Document Number: 2016-13015
Type: Proposed Rule
Date: 2016-06-02
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This 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.
Open Meeting for the Electronic Tax Administration Advisory Committee (ETAAC)
Document Number: 2016-13002
Type: Notice
Date: 2016-06-02
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Electronic Tax Administration Advisory Committee (ETAAC) will be conducted at the Internal Revenue Service Building in Washington, DC. The ETAAC will discuss recommendations for electronic tax administration which will be published in their Annual Report to Congress by June 30, 2016. The IRS will respond to these recommendations. Meeting Date: The meeting will be held on Tuesday, June 21, 2016, beginning at 9:00 a.m. eastern time, ending at approximately 11:30 a.m.
Proposed Collection; Comment Request for Form 3520
Document Number: 2016-13001
Type: Notice
Date: 2016-06-02
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipts of Certain Foreign Gifts.
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