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

Source of Income From Certain Sales of Personal Property
Document Number: 2019-27813
Type: Proposed Rule
Date: 2019-12-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations modifying the rules for determining the source of income from sales of inventory produced within the United States and sold without the United States or vice versa. These proposed regulations also contain new rules for determining the source of income from sales of personal property (including inventory) by nonresidents that are attributable to an office or other fixed place of business that the nonresident maintains in the United States. Finally, these proposed regulations modify certain rules for determining whether foreign source income is effectively connected with the conduct of a trade or business within the United States.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Relating to Relief for Certain Spouses of Military Personnel
Document Number: 2019-27751
Type: Notice
Date: 2019-12-26
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 the requirements relating to the relief and procedures for spouses of U.S. servicemembers who are working in or claiming residence or domicile in a U.S. territory.
Misdirected Direct Deposit Refunds
Document Number: 2019-27653
Type: Proposed Rule
Date: 2019-12-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
These proposed regulations provide guidance on section 6402(n) of the Internal Revenue Code (Code), concerning the procedures for identification and recovery of a misdirected direct deposit refund. The regulations reflect changes to the law made by the Taxpayer First Act. The proposed regulations affect taxpayers who have made a claim for refund, requested the refund be issued as a direct deposit, but did not receive a refund in the account designated on the claim for refund.
Guidance Under Section 6033 Regarding the Reporting Requirements of Exempt Organizations; Hearing
Document Number: 2019-27440
Type: Proposed Rule
Date: 2019-12-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document provides a notice of public hearing on proposed regulations that would update information reporting regulations under section 6033 that are generally applicable to organizations exempt from tax under section 501(a) to reflect statutory amendments and certain grants of reporting relief announced through subregulatory guidance that have been made since the current regulations were adopted, particularly with respect to tax-exempt organizations required to file an annual Form 990 or 990-EZ information return.
Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m)
Document Number: 2019-26116
Type: Proposed Rule
Date: 2019-12-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document sets forth proposed regulations under section 162(m) of the Internal Revenue Code (Code), which limits the deduction for certain employee remuneration in excess of $1,000,000 for federal income tax purposes. These proposed regulations implement the amendments made to section 162(m) by the Tax Cuts and Jobs Act. These proposed regulations would affect publicly held corporations. This document also provides a notice of a public hearing on these proposed regulations.
Guidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition; Guidance Under Section 355(f)
Document Number: 2019-27110
Type: Rule
Date: 2019-12-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final 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. In particular, the final 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. In addition, the final regulations provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The final 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. These regulations affect corporations that distribute the stock or securities of a controlled corporation and the shareholders or security holders of those distributing corporations.
Dividend Equivalents From Sources Within the United States
Document Number: 2019-26977
Type: Rule
Date: 2019-12-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.
Treatment of Payments to Charitable Entities in Return for Consideration
Document Number: 2019-26969
Type: Proposed Rule
Date: 2019-12-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document provides proposed amendments to the regulations under sections 162, 164, and 170 of the Internal Revenue Code (Code). First, the proposed amendments update the regulations under section 162 to reflect current law regarding the application of section 162 to a taxpayer that makes a payment or transfer to an entity described in section 170(c) for a business purpose. Second, the proposed amendments provide safe harbors under section 162 to provide certainty with respect to the treatment of payments made by business entities to an entity described in section 170(c). Third, the proposed amendments provide a safe harbor under section 164 for payments made to an entity described in section 170(c) by individuals who itemize deductions and receive or expect to receive a state or local tax credit in return. Fourth, the proposed amendments update the regulations under section 170 to reflect past guidance and case law regarding the application of the quid pro quo principle under section 170 to benefits received or expected to be received by a donor from a third party.
Foreign Tax Credit Guidance Related to the Tax Cuts and Jobs Act, Overall Foreign Loss Recapture, and Foreign Tax Redeterminations
Document Number: 2019-24848
Type: Rule
Date: 2019-12-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance relating to the determination of the foreign tax credit under the Internal Revenue Code. The guidance relates to changes made to the applicable law by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document finalizes the proposed regulations published on December 7, 2018. This document also finalizes proposed regulations on overall foreign losses that were published on June 25, 2012, and finalizes certain portions of proposed regulations published on November 7, 2007, relating to a U.S. taxpayer's obligation to notify the IRS of a foreign tax redetermination.
Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups
Document Number: 2019-24847
Type: Proposed Rule
Date: 2019-12-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups.
Proposed Collection; Comment Request for Form Project
Document Number: 2019-27029
Type: Notice
Date: 2019-12-16
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 return of excise tax on undistributed income of real estate investment trusts.
Calculation of UBTI for Certain Exempt Organizations
Document Number: C1-2019-26274
Type: Rule
Date: 2019-12-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Relating to Escrow Funds and Other Similar Funds
Document Number: 2019-26914
Type: Notice
Date: 2019-12-13
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 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 the burden related to requirements that escrow accounts, settlement funds, and similar funds be subject to current taxation either as grantor trusts or otherwise.
Information Reporting for Certain Life Insurance Contract Transactions and Modifications to the Transfer for Valuable Consideration Rules; Correction
Document Number: 2019-26867
Type: Rule
Date: 2019-12-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9879) that were published in the Federal Register on Thursday, October 31, 2019. The final regulations provide guidance on new information reporting obligations under section 6050Y related to reportable policy sales of life insurance contracts and payments of reportable death benefits and provide guidance on the amount of death benefits excluded from gross income under section 101 following a reportable policy sale.
Information Reporting for Certain Life Insurance Contract Transactions and Modifications to the Transfer for Valuable Consideration Rules; Correcting Amendment
Document Number: 2019-26866
Type: Rule
Date: 2019-12-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to Treasury Decision 9879, which was published in the Federal Register on Thursday, October 31, 2019. Treasury Decision 9879 contained final regulations providing guidance on new information reporting obligations under section 6050Y related to reportable policy sales of life insurance contracts and payments of reportable death benefits and guidance on the amount of death benefits excluded from gross income under section 101 following a reportable policy sale.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request Relating to Constructive Transfers and Transfers of Property to a Third Party on Behalf of a Spouse
Document Number: 2019-26778
Type: Notice
Date: 2019-12-12
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 the requirements relating to the constructive transfers and transfers of property to a third party on behalf of a spouse.
Proposed Collection; Comment Request for Form 720-CS, Carrier Summary Report, Form 720-TO, Terminal Operator Report, and Form 8809-EX, Request for Extension of Time To File an ExSTARS Information Return
Document Number: 2019-26513
Type: Notice
Date: 2019-12-10
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 proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995. Currently, the IRS is soliciting comments concerning Form 720-CS, Carrier Summary Report, Form 720-TO, Terminal Operator Report, and Form 8809-EX, Request for Extension of Time to File an ExSTARS Information Return.
Calculation of UBTI for Certain Exempt Organizations
Document Number: 2019-26274
Type: Rule
Date: 2019-12-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a final regulation providing guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI).
Additional Rules Regarding Base Erosion and Anti-Abuse Tax
Document Number: 2019-25745
Type: Proposed Rule
Date: 2019-12-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.
Base Erosion and Anti-Abuse Tax
Document Number: 2019-25744
Type: Rule
Date: 2019-12-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations implementing the base erosion and anti-abuse tax, designed to prevent the reduction of tax liability by certain large corporate taxpayers through certain payments made to foreign related parties and certain tax credits. These final regulations also provide reporting requirements related to this tax. This tax was added to the Internal Revenue Code (the ``Code'') as part of the Tax Cuts and Jobs Act. This document finalizes the proposed regulations published on December 21, 2018. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties. The final regulations also affect any reporting corporations required to furnish information relating to certain related-party transactions and information relating to a trade or business conducted within the United States by a foreign corporation.
Proposed Collection; Comment Request for Revenue Procedure 2001-20
Document Number: 2019-26237
Type: Notice
Date: 2019-12-05
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 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 Revenue Procedure 2001- 20, Voluntary Compliance on Alien Withholding Program (``VCAP'').
Proposed Collection; Comment Request for Regulation Project
Document Number: 2019-26236
Type: Notice
Date: 2019-12-05
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 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 Revenue Procedure 2004- 12, Health Insurance Costs of Eligible Individuals.
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request on Application for Extension of Time To File Information Returns
Document Number: 2019-25990
Type: Notice
Date: 2019-12-02
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 the collection of information related to the requirements for reporting on returns regarding payments of interest.
Proposed Collection; Comment Request for Form 8873
Document Number: 2019-25989
Type: Notice
Date: 2019-12-02
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 8873, Extraterritorial Income Exclusion.
Proposed Collection; Comment Request for Revenue Procedure 2007-12
Document Number: 2019-25988
Type: Notice
Date: 2019-12-02
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 Revenue Procedure 2007- 12, Certification for No Information Reporting on the Sale or Exchange of a Principal Residence.
Guidance on Passive Foreign Investment Companies; Hearing Cancellation
Document Number: 2019-25955
Type: Proposed Rule
Date: 2019-12-02
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document cancels a public hearing on proposed regulations under sections 1291, 1297, and 1298 of the Internal Revenue Code (``Code'') regarding the determination of ownership in a passive foreign investment company within the meaning of section 1297(a) (``PFIC'') and the treatment of certain income received or accrued by a foreign corporation and assets held by a foreign corporation for purposes of section 1297.