Internal Revenue Service June 2019 – Federal Register Recent Federal Regulation Documents

Amount Determined Under Section 956 for Corporate United States Shareholders; Correction
Document Number: 2019-13489
Type: Rule
Date: 2019-06-25
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9859) that were published in the Federal Register on Thursday, May 23, 2019. The final regulations reduce the amount determined under section 956 of the Internal Revenue Code with respect to certain domestic corporations.
Proposed Collection; Comment Request for Form Project
Document Number: 2019-13397
Type: Notice
Date: 2019-06-25
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning Cyber Assistant Program (Authorized Cyber Assistant Host Application).
Proposed Collection; Comment Request for Form 8275 and 8275-R
Document Number: 2019-13359
Type: Notice
Date: 2019-06-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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. Currently, the IRS is soliciting comments concerning Form 8275, Disclosure Statement, and Form 8275-R, Regulation Disclosure Statement.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2019-13358
Type: Notice
Date: 2019-06-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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. Currently, the IRS is soliciting comments concerning Settlement Funds.
Proposed Collection; Comment Request for Form Project
Document Number: 2019-13322
Type: Notice
Date: 2019-06-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning information returns of U.S. persons with respect to foreign disregarded entities, and transactions between foreign disregarded entity of a foreign tax owner and the filer on other related entities.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2019-13210
Type: Notice
Date: 2019-06-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning directed withholding and deposit verification, central withholding agreement, and Application for Central Withholding Agreement Less than $10,000.
Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits
Document Number: 2019-12437
Type: Rule
Date: 2019-06-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations, including United States shareholders that are members of a consolidated group. This document also contains final regulations relating to the determination of a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income included in the shareholder's gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, this document contains final regulations relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations.
Guidance Under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income)
Document Number: 2019-12436
Type: Proposed Rule
Date: 2019-06-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. In addition, this document contains proposed regulations under the global intangible low-taxed income provisions regarding gross income that is subject to a high rate of foreign tax. The proposed regulations would affect United States persons that own stock of foreign corporations through domestic partnerships and United States shareholders of foreign corporations.
Health Reimbursement Arrangements and Other Account-Based Group Health Plans
Document Number: 2019-12571
Type: Rule
Date: 2019-06-20
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 sets forth final rules to expand opportunities for working men and women and their families to access affordable, quality healthcare through changes to rules under various provisions of the Public Health Service Act (PHS Act), the Employee Retirement Income Security Act (ERISA), and the Internal Revenue Code (Code) regarding health reimbursement arrangements (HRAs) and other account-based group health plans. Specifically, the final rules allow integrating HRAs and other account-based group health plans with individual health insurance coverage or Medicare, if certain conditions are satisfied (an individual coverage HRA). The final rules also set forth conditions under which certain HRAs and other account-based group health plans will be recognized as limited excepted benefits. Also, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) are finalizing rules regarding premium tax credit (PTC) eligibility for individuals offered an individual coverage HRA. In addition, the Department of Labor (DOL) is finalizing a clarification to provide assurance that the individual health insurance coverage for which premiums are reimbursed by an individual coverage HRA or a qualified small employer health reimbursement arrangement (QSEHRA) does not become part of an ERISA plan, provided certain safe harbor conditions are satisfied. Finally, the Department of Health and Human Services (HHS) is finalizing provisions to provide a special enrollment period (SEP) in the individual market for individuals who newly gain access to an individual coverage HRA or who are newly provided a QSEHRA. The goal of the final rules is to expand the flexibility and use of HRAs and other account-based group health plans to provide more Americans with additional options to obtain quality, affordable healthcare. The final rules affect employees and their family members; employers, employee organizations, and other plan sponsors; group health plans; health insurance issuers; and purchasers of individual health insurance coverage.
Section 199A Rules for Cooperatives and Their Patrons
Document Number: 2019-11501
Type: Proposed Rule
Date: 2019-06-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
These proposed regulations provide guidance to cooperatives to which sections 1381 through 1388 of the Internal Revenue Code (Code) apply (Cooperatives) and their patrons regarding the deduction for qualified business income (QBI) under section 199A(a) of the Code as well as guidance to specified agricultural or horticultural cooperatives (Specified Cooperatives) and their patrons regarding the deduction for domestic production activities under section 199A(g) of the Code. These proposed regulations also provide guidance on section 199A(b)(7), the rule requiring patrons of Specified Cooperatives to reduce their deduction for QBI under section 199A(a). In addition, these proposed regulations include a single definition of patronage and nonpatronage under section 1388 of the Code. Finally, these proposed regulations propose to remove the final regulations, and withdraw the proposed regulations that have not been finalized, under former section 199. These proposed regulations affect Cooperatives as well as patrons that are individuals, partnerships, S corporations, trusts, and estates engaged in domestic trades or businesses.
Electing Small Business Trusts With Nonresident Aliens as Potential Current Beneficiaries
Document Number: 2019-12639
Type: Rule
Date: 2019-06-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations regarding the statutory expansion of the class of permissible potential current beneficiaries (PCBs) of an electing small business trust (ESBT) to include nonresident aliens (NRAs). In particular, the final regulations ensure that the income of an S corporation will continue to be subject to U.S. Federal income tax when an NRA is a deemed owner of a grantor trust that elects to be an ESBT.
Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
Document Number: 2019-12442
Type: Rule
Date: 2019-06-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations under section 245A of the Internal Revenue Code (the ``Code'') that limit the dividends received deduction available for certain dividends received from current or former controlled foreign corporations. This document also contains temporary regulations that limit the applicability of the exception to foreign personal holding company income for certain dividends received by upper-tier controlled foreign corporations from lower-tier controlled foreign corporations and temporary regulations under section 6038 to facilitate administration of certain rules in the temporary regulations. The temporary regulations affect certain U.S. persons that are domestic corporations that receive certain dividends from current or former controlled foreign corporations or are United States shareholders of upper-tier controlled foreign corporations that receive certain dividends from lower-tier controlled foreign corporations. 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.
Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
Document Number: 2019-12441
Type: Proposed Rule
Date: 2019-06-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Rules and Regulations section of this issue of the Federal Register contains temporary regulations under the Internal Revenue Code (the ``Code'') that limit the dividends received deduction available for certain dividends received from current or former controlled foreign corporations. The temporary regulations also contain rules that limit the applicability of the exception to foreign personal holding company income for certain dividends received by upper-tier controlled foreign corporations from lower-tier controlled foreign corporations and temporary regulations to facilitate administration of certain rules in the temporary regulations. The temporary regulations affect certain U.S. persons that are domestic corporations that receive certain dividends from current or former controlled foreign corporations or are United States shareholders of upper-tier controlled foreign that receive certain dividends from lower-tier controlled foreign corporations.
Modification of Discounting Rules for Insurance Companies
Document Number: 2019-12172
Type: Rule
Date: 2019-06-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations on discounting rules for unpaid losses and estimated salvage recoverable of insurance companies for Federal income tax purposes. The final regulations update and replace existing regulations to implement recent legislative changes to the Internal Revenue Code (Code) and make a technical improvement to the derivation of loss payment patterns used for discounting. The final regulations affect entities taxable as insurance companies.
Proposed Collection; Comment Request for Form 8824
Document Number: 2019-12477
Type: Notice
Date: 2019-06-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning Form 8824, Like-Kind Exchanges.
Contributions in Exchange for State or Local Tax Credits
Document Number: 2019-12418
Type: Rule
Date: 2019-06-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a final regulation under section 170 of the Internal Revenue Code (Code). The final regulation provides 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 provides a final regulation under section 642(c) to apply similar rules to payments made by a trust or decedent's estate.
Proposed Collection; Comment Request for Form Project
Document Number: 2019-12190
Type: Notice
Date: 2019-06-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning application for enrollment to practice before the Internal Revenue Service.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2019-12186
Type: Notice
Date: 2019-06-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning real estate mortgage investment conduits.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2019-12160
Type: Notice
Date: 2019-06-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning reverse like-kind exchanges.
Open Meeting of the Taxpayer Advocacy Panel's Tax Forms and Publications Project Committee
Document Number: 2019-12002
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's 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's Notices and Correspondence Project Committee
Document Number: 2019-12001
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's 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's Toll-Free Phone Line Project Committee
Document Number: 2019-12000
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's 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.
Open Meeting of the Taxpayer Advocacy Panel Taxpayer Assistance Center Project Committee
Document Number: 2019-11999
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's Taxpayer Assistance Center 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: 2019-11998
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's 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 Joint Committee
Document Number: 2019-11997
Type: Notice
Date: 2019-06-07
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's Special Projects Committee
Document Number: 2019-11996
Type: Notice
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's 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.
Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]
Document Number: 2019-11753
Type: Rule
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final 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 (PATH Act). The final regulations impose corporate-level tax on certain transactions in which property of a C corporation becomes the property of a REIT. The final regulations affect RICs, REITs, C corporations the property of which becomes the property of a RIC or a REIT, and their shareholders.
Exception for Interests Held by Foreign Pension Funds
Document Number: 2019-11291
Type: Proposed Rule
Date: 2019-06-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations regarding the exception from taxation with respect to gain or loss of a qualified foreign pension fund attributable to certain interests in United States real property. The proposed regulations also include rules for certifying that a qualified foreign pension fund is not subject to withholding on certain dispositions of, and distributions with respect to, certain interests in United States real property. The proposed regulations affect certain holders of certain interests in United States real property and withholding agents that are required to withhold tax on certain dispositions of, and distributions with respect to, such property.
Credit for Renewable Electricity Production and Refined Coal Production, and Publication of Inflation Adjustment Factor and Reference Prices for Calendar Year 2019
Document Number: 2019-11810
Type: Notice
Date: 2019-06-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The 2019 inflation adjustment factor and reference prices are used in determining the availability of the credit for renewable electricity production and refined coal production under section 45. As of October 2, 2018, the credit period for small irrigation power electricity production expired.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request for Nonqualified Deferred Compensation and IRC Section 409A
Document Number: 2019-11808
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning nonqualified deferred compensation and IRC section 409A.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request for Form 4506T-EZ and Form 4506T-EZ(SP)
Document Number: 2019-11805
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning Form 4506T-EZ, Short Form Request for Individual Tax Return Transcript, and 4506T-EZ(SP), Formulario Abreviado para la Solicitud de un Trasunto de la Declaracion de Impuestos Personales.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Concerning Elections for Certain Transactions Under Section 336(e)
Document Number: 2019-11771
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning elections for certain transactions under section 336(e).
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Concerning Guidance Regarding Deduction and Capitalization of Expenditures
Document Number: 2019-11770
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning guidance regarding deduction and capitalization of expenditures.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Concerning Source of Income From Certain Space and Ocean Activities; Source of Communications Income
Document Number: 2019-11769
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning source of income from certain space and ocean activities; source of communications income.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Concerning Information Reporting for Form 8870
Document Number: 2019-11767
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning information reporting for Form 8870, Information Return for Transfers Associated With Certain Personal Benefit Contracts.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Concerning Information Reporting for Debt Instruments With Original Issue Discount; Contingent Payments; Anti-Abuse Rule and Third-Party Network Transactions
Document Number: 2019-11766
Type: Notice
Date: 2019-06-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the 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. Currently, the IRS is soliciting comments concerning information reporting for debt instruments with original issue discount; contingent payments; anti-abuse rule.
Electronic Tax Administration Advisory Committee; Notice of Meeting
Document Number: 2019-11294
Type: Notice
Date: 2019-06-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Electronic Tax Administration Advisory Committee (ETAAC) will hold a public meeting on Wednesday, June 19, 2019.
Proposed Collection; Comment Request for Form 4461, 4461-A, and 4461-B
Document Number: 2019-11435
Type: Notice
Date: 2019-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning Form 4461, Application for Approval of Standardized or Nonstandardized Pre-Approved Defined Contribution Plans; Form 4461-A, Application for Approval of Master or Prototype or Volume Submitter Defined Benefit Plan; and, Form 4461-B, Application for Approval of Standardized or Nonstandardized Pre- Approved Plans.
Proposed Collection; Comment Request for Notice 97-45
Document Number: 2019-11434
Type: Notice
Date: 2019-06-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, 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 information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning Notice 97-45, Highly Compensated Employee Definition.
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