Internal Revenue Service – Federal Register Recent Federal Regulation Documents

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Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder
Document Number: 2020-17549
Type: Rule
Date: 2020-09-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document finalizes the proposed regulations published on October 2, 2019. The final regulations affect United States persons that have ownership interests in, or that make or receive payments to or from, certain foreign corporations.
Proposed Collection; Comment Request for Application for Approval of Prototype Simplified Employee Pension (SEP) or Savings Incentive Match Plan for Employees of Small Employers (SIMPLE IRA Plan)
Document Number: 2020-20605
Type: Notice
Date: 2020-09-21
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 information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning Form 5306-A, Application for Approval of Prototype Simplified Employee Pension (SEP) or Savings Incentive Match Plan for Employees of Small Employers (SIMPLE IRA Plan).
Proposed Collection; Comment Request for Form 5330
Document Number: 2020-20410
Type: Notice
Date: 2020-09-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Return of Excise Taxes Related to Employee Benefit Plans.
Proposed Collection; Comment Request for Form 13560
Document Number: 2020-20413
Type: Notice
Date: 2020-09-16
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Health Plan Administrator (HPA) Return of Funds.
Limitation on Deduction for Business Interest Expense; Allocation of Interest Expense by Passthrough Entities; Dividends Paid by Regulated Investment Companies; Application of Limitation on Deduction for Business Interest Expense to United States Shareholders of Controlled Foreign Corporations and to Foreign Persons With Effectively Connected Income
Document Number: 2020-16532
Type: Proposed Rule
Date: 2020-09-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This notice of proposed rulemaking provides rules concerning the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the provisions commonly known as the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, and the Coronavirus Aid, Relief, and Economic Security Act, which was enacted on March 27, 2020. Specifically, these proposed regulations address application of the limitation in contexts involving passthrough entities, regulated investment companies (RICs), United States shareholders of controlled foreign corporations, and foreign persons with effectively connected income in the United States. These proposed regulations also provide guidance regarding the definitions of real property development, real property redevelopment, and a syndicate. These proposed regulations affect taxpayers that have business interest expense, particularly passthrough entities, their partners and shareholders, as well as foreign corporations and their United States shareholders and foreign persons with effectively connected income. These proposed regulations also affect RICs that have business interest income, RIC shareholders that have business interest expense, and members of a consolidated group.
Limitation on Deduction for Business Interest Expense
Document Number: 2020-16531
Type: Rule
Date: 2020-09-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations providing guidance about the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the provisions commonly known as the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, and the Coronavirus Aid, Relief, and Economic Security Act, which was enacted on March 27, 2020. The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation, and how the limitation applies in consolidated group, partnership, international, and other contexts.
Open Meeting of the Taxpayer Advocacy Panel Joint Committee
Document Number: 2020-19972
Type: Notice
Date: 2020-09-10
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: 2020-19971
Type: Notice
Date: 2020-09-10
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.
Open Meeting of the Taxpayer Advocacy Panel Taxpayer Communications Project Committee
Document Number: 2020-19970
Type: Notice
Date: 2020-09-10
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 Taxpayer Assistance Center Improvements Project Committee
Document Number: 2020-19969
Type: Notice
Date: 2020-09-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's Taxpayer Assistance Center Improvements 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: 2020-19968
Type: Notice
Date: 2020-09-10
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 Lines Project Committee
Document Number: 2020-19967
Type: Notice
Date: 2020-09-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's Toll-Free Phone Lines 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 Tax Forms and Publications Project Committee
Document Number: 2020-19966
Type: Notice
Date: 2020-09-10
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.
Proposed Collection; Comment Request for Form 15254
Document Number: 2020-19958
Type: Notice
Date: 2020-09-10
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 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 15058, Application for Security Summit Membership.
Proposed Collection; Comment Request for United States Gift (and Generation-Skipping Transfer) Tax Return
Document Number: 2020-19930
Type: Notice
Date: 2020-09-10
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 United States gift (and generation-skipping transfer) tax return.
Art Advisory Panel-Notice of Closed Meeting
Document Number: 2020-19867
Type: Notice
Date: 2020-09-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Closed meeting of the Art Advisory Panel will be held virtually by WebEx.
Senior Executive Service Performance Review Board
Document Number: 2020-19859
Type: Notice
Date: 2020-09-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
To announce a list of senior executives who comprise a standing roster that will serve on IRS's Fiscal Year 2020 Senior Executive Service (SES) Performance Review Boards.
Proposed Collection; Comment Request for Disabled Access Credit
Document Number: 2020-19858
Type: Notice
Date: 2020-09-09
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 the disabled access credit.
Proposed Collection; Comment Request for Form 4952
Document Number: 2020-19857
Type: Notice
Date: 2020-09-09
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 4952, Investment Interest Expense Deduction.
Proposed Collection; Comment Request for Form 15227
Document Number: 2020-19728
Type: Notice
Date: 2020-09-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Application for an Identity Protection Personal Identification Number.
Proposed Collection; Comment Request for Regulation Project
Document Number: 2020-19727
Type: Notice
Date: 2020-09-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Entry of Taxable Fuel.
Proposed Collection; Comment Request for New Technologies in Retirement Plans
Document Number: 2020-19720
Type: Notice
Date: 2020-09-08
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 new technologies in retirement plans.
Proposed Collection; Comment Request for Form 8946
Document Number: 2020-19710
Type: Notice
Date: 2020-09-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 the PTIN Supplemental Application For Foreign Persons Without a Social Security Number.
Appointment of Members of the Legal Division to the Performance Review Board, Internal Revenue Service
Document Number: 2020-19613
Type: Notice
Date: 2020-09-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Appointment of Members of the Legal Division to the Performance Review Board, Internal Revenue Service
Document Number: 2020-19612
Type: Notice
Date: 2020-09-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Nuclear Decommissioning Funds
Document Number: 2020-16955
Type: Rule
Date: 2020-09-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants and the use of the amounts in those trusts to decommission nuclear plants. The regulations revise and clarify certain provisions in existing regulations to address issues that have arisen as more nuclear plants have begun the decommissioning process.
Proposed Collection; Comment Request for the Annual Return/Report of Employee Benefit Plan
Document Number: 2020-19449
Type: Notice
Date: 2020-09-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 the Annual Return/ Report of Employee Benefit Plan.
Proposed Collection; Comment Request for Application To Participate in the IRS Acceptance Program
Document Number: 2020-19362
Type: Notice
Date: 2020-09-02
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), in accordance with the Paperwork Reduction Act of 1995 (PRA 95), provides the general public and Federal agencies with an opportunity to comment on continuing collections of information. This helps the IRS assess the impact of its information collection requirements and minimize the reporting burden on the public and helps the public understand the IRS's information collection requirements and provide the requested data in the desired format. The IRS is soliciting comments concerning Application to Participate in the IRS Acceptance Agent Program. Form 13551 is used to gather information to determine applicant's eligibility in the Acceptance Agent Program.
Proposed Collection; Comment Request Concerning Procedures for Requesting Competent Authority Assistance Under Tax Treaties
Document Number: 2020-19361
Type: Notice
Date: 2020-09-02
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 continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning procedures for requesting competent authority assistance under tax treaties.
Carryback of Consolidated Net Operating Losses; Correcting Amendment
Document Number: 2020-16985
Type: Rule
Date: 2020-08-28
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to Treasury Decision 9900, which was published in the Federal Register on Wednesday, July 8, 2020. Treasury Decision 9900 contained temporary regulations that permit consolidated groups that acquire new members that were members of another consolidated group to elect in a year subsequent to the year of acquisition to waive all or part of the pre-acquisition portion of an extended carryback period under section 172 of the Internal Revenue Code (Code) for certain losses attributable to the acquired members if there is a retroactive statutory extension of the NOL carryback period under section 172.
Privacy Act of 1974
Document Number: 2020-18863
Type: Notice
Date: 2020-08-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Pursuant to the Privacy Act of 1974, as amended, and the Office of Management and Budget (OMB) Guidelines on the Conduct of Matching Programs, notice is hereby given of the conduct of the Internal Revenue Service (IRS) Disclosure of Information to Federal, State and Local Agencies (DIFSLA) Computer Matching Program.
Coordination of Extraordinary Disposition and Disqualified Basis Rules
Document Number: 2020-18544
Type: Proposed Rule
Date: 2020-08-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations under sections 245A and 951A of the Internal Revenue Code (the ``Code'') that coordinate the extraordinary disposition rule under section 245A of the Internal Revenue Code (the ``Code'') with the disqualified basis rule under section 951A of the Code. This document also contains proposed regulations under section 6038 of the Code regarding information reporting to facilitate administration of the proposed regulations. The proposed regulations affect corporations that are subject to the extraordinary disposition rule and the disqualified basis rule.
Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
Document Number: 2020-18543
Type: Rule
Date: 2020-08-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under sections 245A and 954 of the Internal Revenue Code (the ``Code'') that limit the deduction for certain dividends received by United States persons from foreign corporations under section 245A and the exception to subpart F income under section 954(c)(6) for certain dividends received by controlled foreign corporations. This document also contains final regulations under section 6038 of the Code regarding information reporting to facilitate administration of the final regulations. 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 proposed regulations published on June 18, 2019, and removes temporary regulations published on the same date.
Proposed Collection; Comment Request for Form 211
Document Number: 2020-18322
Type: Notice
Date: 2020-08-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Application for Award for Original Information.
Proposed Collection; Comment Request for Form 8941
Document Number: 2020-18321
Type: Notice
Date: 2020-08-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Credit for Small Employer Health Insurance Premiums.
Proposed Collection; Comment Request for Form 8963
Document Number: 2020-18320
Type: Notice
Date: 2020-08-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service (IRS), 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 Report of Health Insurance Provider Information.
Rollover Rules for Qualified Plan Loan Offset Amounts
Document Number: 2020-16564
Type: Proposed Rule
Date: 2020-08-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document sets forth proposed regulations relating to amendments made to section 402(c) of the Internal Revenue Code (Code) by section 13613 of the Tax Cuts and Jobs Act, Public Law 115-97 (131 Stat. 2054) (TCJA). Section 13613 of TCJA provides an extended rollover period for a qualified plan loan offset, which is a type of plan loan offset. These regulations affect participants, beneficiaries, sponsors, and administrators of qualified employer plans.
Certain Outbound Property Transfers by Domestic Corporations; Certain Stock Distributions by Domestic Corporations; Correcting Amendment
Document Number: 2020-16354
Type: Rule
Date: 2020-08-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to a Treasury Decision 9614, which was published in the Federal Register on Tuesday, March 19, 2013. Treasury Decision 9614 contained final regulations that apply to transfers of certain property by a domestic corporation to a foreign corporation in certain nonrecognition exchanges, or to distributions of stock of certain foreign corporations by a domestic corporation in certain nonrecognition distributions.
Guidance Under Section 1061
Document Number: 2020-17108
Type: Proposed Rule
Date: 2020-08-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance under section 1061 of the Internal Revenue Code (Code). Section 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains. An applicable partnership interest is an interest in a partnership that is transferred to or held by a taxpayer, directly or indirectly, in connection with the performance of substantial services by the taxpayer, or any other related person, in any applicable trade or business. These proposed regulations also amend existing regulations on holding periods to clarify the holding period of a partner's interest in a partnership that includes in whole or in part an applicable partnership interest and/or a profits interest. These regulations affect taxpayers who directly or indirectly hold applicable partnership interests in partnerships and the passthrough entities in which the applicable partnership interest is held, directly or indirectly.
Base Erosion and Anti-Abuse Tax; Correcting Amendment
Document Number: 2020-16383
Type: Rule
Date: 2020-08-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9885) that were published in the Federal Register on Friday, December 6, 2019. The 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.
Open Meeting of the Taxpayer Advocacy Panel Taxpayer Communications Project Committee
Document Number: 2020-17671
Type: Notice
Date: 2020-08-13
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's Toll-Free Phone Lines Project Committee
Document Number: 2020-17668
Type: Notice
Date: 2020-08-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's Toll-Free Phone Lines 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: 2020-17667
Type: Notice
Date: 2020-08-13
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 Tax Forms and Publications Project Committee
Document Number: 2020-17666
Type: Notice
Date: 2020-08-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel's (TAP) Tax Forms and Publications Project Committee will be conducted. The TAP 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: 2020-17665
Type: Notice
Date: 2020-08-13
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 Special Projects Committee
Document Number: 2020-17664
Type: Notice
Date: 2020-08-13
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.
Rules Regarding Certain Hybrid Arrangements; Correcting Amendment
Document Number: 2020-15842
Type: Rule
Date: 2020-08-12
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations Treasury Decision 9896 that were published in the Federal Register on Wednesday, April 8, 2020. The final regulations providing guidance regarding hybrid dividends and certain amounts paid or accrued pursuant to hybrid arrangements, which generally involve arrangements whereby U.S. and foreign tax law classify a transaction or entity differently for tax purposes.
Treatment of Payments to Charitable Entities in Return for Consideration
Document Number: 2020-17393
Type: Rule
Date: 2020-08-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under sections 162, 164, and 170 of the Internal Revenue Code (Code). First, the final regulations update the regulations under section 162 to reflect current law regarding the application of section 162 to taxpayers that make payments or transfers for business purposes to entities described in section 170(c). Second, the final regulations provide safe harbors under section 162 to provide certainty with respect to the treatment of payments made by business entities to entities described in section 170(c). Third, the final regulations 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 final regulations 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 a donor who receives or expects to receive benefits from a third party. These regulations affect taxpayers who make transfers to entities described in section 170(c) for business purposes, and taxpayers who receive State or local tax credits in exchange for transfers to such entities or who receive other third-party benefits in exchange for transfers to such entities.
Guidance Involving Hybrid Arrangements and the Allocation of Deductions Attributable to Certain Disqualified Payments Under Section 951A (Global Intangible Low-Taxed Income); Correction
Document Number: 2020-15857
Type: Proposed Rule
Date: 2020-08-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on April 8, 2020. The proposed regulations that adjust hybrid deduction accounts to take into account earnings and profits of a controlled foreign corporation that are included in income by a United States shareholder.
Certain Non-Government Persons Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) Contractor
Document Number: 2020-16912
Type: Proposed Rule
Date: 2020-08-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document withdraws a notice of proposed rulemaking (REG- 132434-17) published in the Federal Register on March 28, 2018, which contained proposed regulations that addressed the participation of persons described under section 6103(n) of the Code in the interview of a summoned witness and excluded certain non-government attorneys from participating in an IRS examination. This document also contains new proposed regulations to implement section 7602(f) of the Internal Revenue Code (Code), which was added to the Code by the Taxpayer First Act of 2019. The new proposed regulations implement new section 7602(f) regarding the persons who may be provided books, papers, records, or other data obtained pursuant to section 7602 for the sole purpose of providing expert evaluation and assistance to the IRS, and continue to propose limitations on the types of non-governmental attorneys to whom, under the authority of section 6103(n), any books, papers, records, or other data obtained pursuant to section 7602 may be provided. The new proposed regulations also propose to prohibit any IRS contractors from asking a summoned person's representative to clarify an objection or assertion of privilege. The regulations affect these persons.