Internal Revenue Service November 14, 2023 – Federal Register Recent Federal Regulation Documents

Recognition and Deferral of Section 987 Gain or Loss; Comment Period Reopening
Document Number: 2023-24650
Type: Proposed Rule
Date: 2023-11-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury and the IRS are reopening the comment period for REG-128276-12, published in the Federal Register on December 8, 2016, relating to the determination and recognition of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit.
Income and Currency Gain or Loss With Respect to a Qualified Business Unit
Document Number: 2023-24649
Type: Proposed Rule
Date: 2023-11-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations relating to the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit. These proposed regulations include an election to treat all items of a qualified business unit as marked items (subject to a loss suspension rule), an election to recognize all foreign currency gain or loss with respect to a qualified business unit on an annual basis, and a new transition rule.
Taxes on Taxable Distributions From Donor Advised Funds Under Section 4966
Document Number: 2023-24982
Type: Proposed Rule
Date: 2023-11-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations regarding excise taxes on taxable distributions made by a sponsoring organization from a donor advised fund (DAF), and on the agreement of certain fund managers to the making of such distributions. The proposed regulations would provide guidance regarding DAFs and taxable distributions. The proposed regulations generally would apply to certain organizations, including community foundations and other charitable organizations, that maintain one or more DAFs, and to other persons involved with the DAFs, including donors, donor-advisors, related persons, and certain fund managers.
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