Small Business Taxes & Management^TM--Copyright 2012, A/N Group, Inc.

Consolidated Returns

1. Regulations regarding the application of Sec. 172(h) to a consolidated group.

2. Regulations under Sec. 1502 affecting consolidated groups, including regulations regarding loss transfers of member stock.

3. Final regulations under Sec. 1.1502-77 relating to the status as agent of the consolidated group. Proposed regulations were published on May 30, 2012.

4. Final regulations under Sec. 1.1502-91 regarding the redetermination of the consolidated net unrealized built-in gain and loss. Proposed regulations were published on October 24, 2011.

Corporations and Their Shareholders

1. Final regulations under Sec. 108(i). Temporary and proposed regulations were published on August 13, 2010.

2. Regulations under Secs. 301, 302 and 358 regarding the recovery and allocation of basis in redemptions, organizations, and reorganizations. Proposed regulations were published on January 21, 2009.

3. Final regulations under Sec. 312 regarding the allocation of earnings and profits between a transferor and a transferee corporation when assets are transferred in connection with a reorganization. Proposed regulations were published on April 16, 2012.

4. Guidance under Secs. 332, 351, and 368 regarding transactions involving the transfer of or receipt of no net equity value. Proposed regulations were published on March 10, 2005.

5. Final regulations enabling elections for certain transactions under Sec. 336(e). Proposed regulations were published on August 25, 2008.

6. Final regulations under Sec. 337(dd) related to Real Estate Investment Trusts (REITs) and Regulated Investment Companies (RICs). Proposed regulations were published on April 16, 2012. 7. Guidance regarding divisive transactions under Sec. 355 and related provisions.

8. Regulations relating to the active trade or business requirement under Sec. 355(b). Proposed regulations were published on May 7, 2008.

9. Final regulations regarding predecessors and successors under Sec. 355(e). Proposed regulations were published on November 22, 2004.

10. Regulations under Sec. 362(e) regarding the importation or duplication of losses. Notice 2005-70 on elections under Sec. 362(e)(2)(C) was published on October 11, 2005. Proposed regulations were published on October 23, 2006.

11. Regulations under Sec. 368(a)(1)(F). Proposed regulations were published on August 12, 2004.

12. Guidance regarding maintaining and obtaining employer identification numbers (EINs) when an entity obtains or loses corporate status, and in reorganizations under Sec. 368(a)(1)(F).

13. Final regulations under Sec. 382 regarding the application of the segregation rules to small shareholders. Proposed regulations were published on November 23, 2011.

14. Guidance regarding the treatment of non-stock under Sec. 382.

15. Regulations regarding the scope and application of Sec. 597.

Employee Benefits

A. Retirement Benefits

1. Guidance on exceptions to additional tax under Sec. 72(t) on early distributions from retirement plans and IRAs.

2. Regulations on the application of the normal retirement age regulations under Sec. 401(a) to governmental plans. A request for comments was published in Notice 2012-29, 2012-18 IRB, and in Notice 2007-69, 2007-35 IRB.

3. Revenue Procedure under Secs. 401(a) and 403(a) updating interim amendment procedures in Revenue Procedure 2007-44.

4. Final regulations under Sec. 401(a)(9) on deferred annuities. Proposed regulations were published on February 3, 2012.

5. Final regulations on suspension or reduction of safe harbor contributions under Sec. 401(k) and (m). Proposed regulations were published on May 18, 2009.

6. Guidance under Sec. 402 on transfers from foreign retirement plans.

7. Final regulations under Sec. 402(a) regarding the treatment of incidental benefits provided under a qualified plan. Proposed regulations were published on August 20, 2007.

8. Guidance under Sec. 402(c) on distributions that are disbursed to multiple destinations.

9. Regulations under Sec. 402A on distributions from designated Roth accounts that are disbursed to multiple destinations.

10. Revenue Procedure on Sec. 403(b) plans.

11. Guidance on rules applicable to IRAs under Secs. 408 and 408A.

12. Guidance on rules applicable to ESOPs under Secs. 409 and 4975.

13. Guidance updating regulations for service credit and vesting under Sec. 411.

14. Final regulations relating to hybrid plans under Secs. 411(a)(13) and 411(b)(5), as added by the Pension Protection Act of 2006. Proposed regulations were published on October 19, 2010.

15. Guidance relating to conforming amendments adopted in connection with final regulations under Secs. 411(a)(13) and 411(b)(5), as added by the Pension Protection Act of 2006.

16. Guidance on issues relating to pension equity plans.

17. Final regulations providing a limited exception under Sec. 411(d)(6) for certain optional forms of benefits under a defined benefit plan for plan sponsors in bankruptcy. Proposed regulations were published on June 21, 2012.

18. Regulations on the definition of governmental plan under Sec. 414(d). ANPRM was published on November 8, 2011.

19. Regulations on the status of Indian tribal governmental plans as a governmental plan under Sec. 414(d). ANPRM was published on November 8, 2011.

20. Guidance on pick-up arrangements under Sec. 414(h)(2).

21. Regulations on eligible combined plans under Sec. 414(x), as added by the Pension Protection Act of 2006.

22. Final regulations under Sec. 417(e) to simplify the treatment of optional forms of benefit that are paid partly in the form of an annuity and partly in a more accelerated form. Proposed regulations were published on February 3, 2012.

23. Final regulations on determination of minimum required contributions under Sec. 430, as added by the Pension Protection Act of 2006. Proposed regulations were published on April 15, 2008.

24. Revenue Procedure under Sec. 430 relating to approval for funding method changes to reflect changes to the minimum funding requirements made by the Pension Protection Act of 2006.

25. Regulations on additional issues relating to funding and related rules for single-employer plans under Secs. 430 and 436, as added by the Pension Protection Act of 2006.

26. Notice on additional issues relating to funding and benefit limitation relief for single-employer plans under the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010.

27. Guidance on funding rules in the Highway Investment, Job Creation, and Economic Growth Act of 2012 (Division D of MAP-21).

28. Guidance on funding rules for multiemployer plans under Sec. 432, as added by the Pension Protection Act of 2006.

29. Guidance under Sec. 3405 regarding distributions made to payees with an address outside the United States.

30. Final regulations to designate the Form 8955-SSA as the form to satisfy the Sec. 6057 reporting requirements. Proposed regulations were published on June 21, 2012.

31. Guidance under Secs. 6057, 6058, and 6059 for late filers of Form 5500 series.

32. Regulations under Secs. 6057, 6058, and 6059 regarding electronic filing of Form 5500.

33. Revenue Procedure updating Revenue Procedure 2007-44 for determination letters for individually designed plans.

34. Guidance on group trusts under Revenue Rulings 81-100 and 2011-1. A request for comments was published in Notice 2012-6, 2012-3 IRB.

35. Notice under Sec. 101(j) of the Employee Retirement Income Security Act of 1974 (ERISA) regarding notice requirements applicable to single-employer plans that become subject to funding-based benefit limitations, as added by the Pension Protection Act of 2006.

36. Guidance facilitating rollovers into retirement plans.

37. Additional guidance on issues relating to lifetime income from retirement plans.

38. Guidance on certain issues related to multiple employer plans

39. Revenue Procedure updating Employee Plans Compliance Resolution System (EPCRS).

B. Executive Compensation, Health Care and Other Benefits, and Employment Taxes.

1. Guidance under Sec. 45R as added by Sec. 1421 of the Patient Protection and Affordable Care Act.

2. Revenue Ruling under Sec. 62(c) on wage recharacterization.

3. Final regulations under Sec. 83 to incorporate the holding in Revenue Ruling 2005-48. Proposed regulations were published on May 29, 2012.

4. Final regulations on cafeteria plans under Sec. 125.

5. Guidance under Sec. 132(f) on the use of electronic forms of fare media to distribute qualified transportation fringe benefits. A request for comments was published in Notice 2012-58, 2012-24 IRB. 6. Final regulations under Sec. 162(m) on the stock-based compensation aggregate limit rule under Treas. Reg. Sec. 1.162-27(e)(2), and the transition relief under Treas. Reg. Sec. 1.162-27(f)(1). Proposed regulations were published June 24, 2011.

7. Guidance under Sec. 162(m)(6), as added by Sec. 9014 of the ACA.

8. Guidance under Sec. 223(c)(2)(C) on HSAs regarding certain services required to be provided without cost sharing under PHS Act Sec. 2713, as incorporated into the Code by Sec. 9815.

9. Guidance under Secs. 280G and 4999(a) on change in ownership.

10. Guidance on application of Sec. 402(b) to participants in foreign nonqualified deferred compensation plans.

11. Regulations under Sec. 404 on the application of the "in which or with which ends" rule and the exceptions to that rule in Sec. 1.404(a)-12(b).

12. Final regulations on income inclusion under Sec. 409A. Proposed regulations were published on December 8, 2008.

13. Guidance on application of Sec. 409A to certain transactions involving compensatory stock options and a merger or acquisition.

14. Notice on the application of Sec. 409A(b), as amended by the Pension Protection Act of 2006.

15. Revenue Ruling under Sec. 419A on the definition of post-retirement medical benefits.

16. Regulations amending Sec. 1.419A-2T relating to collectively-bargained welfare benefit funds.

17. Revenue Ruling under Sec. 424(c)(1)(B) on whether there is a disposition of Incentive Stock Option or Employee Stock Purchase Plan shares when boot is received by a target shareholder in a Sec. 368(a)(1) reorganization.

18. Regulations under Sec. 457(f) on ineligible plans.

19. Regulations under Sec. 512 explaining how to compute unrelated business taxable income of voluntary employees' beneficiary associations described in Sec. 501(c)(9).

20. Guidance on the employee retention credit under Sec. 1400R.

21. Regulations under Secs. 3101(b), 3102(f), and 1401(b) on Additional Medicare Tax on employees and self-employed individuals as added by Sec. 9015 of the ACA.

22. Final regulations under Sec. 3504 on reporting employment taxes for home care service recipients. Proposed regulations were published on January 13, 2010.

23. Regulations under Sec. 3504 designating certain parties who file employment tax returns under their EINs for their clients' workers as persons required to perform acts of employers.

24. Revenue procedure under Sec. 3504 updating and consolidating existing guidance related to the procedures for authorizing agents to perform employment tax acts on behalf of an employer.

25. Final regulations under Secs. 4375-4377, as added by § 6301(e)(2)(A) of the ACA to fund the Patient-Centered Outcomes Research Trust Fund. Proposed regulations were published on April 17, 2012.

26. Regulations under Sec. 4980G on interaction of Sec. 4980G and Sec. 125 with respect to comparable employer contributions to employees' HSAs.

27. Regulations on shared responsibility for employers regarding health coverage under § 4980H, as added by Sec. 1513 of the ACA.

28. Notice for determining full-time employees for purposes of shared responsibility for employers regarding health coverage under Sec. 4980H.

29. Regulations on the reporting requirements under Sec. 6056, as added by Sec. 1514 of the ACA.

30. Guidance under Sec. 6402 on employee consents obtained by employer to claim a refund of FICA taxes.

Excise Tax

1. Regulations under Secs. 4051 and 4071 on heavy trucks, tractors, trailers, and tires.

2. Regulations under Sec. 4082 (as amended by the American Jobs Creation Act of 2004) on diesel fuel and kerosene that is dyed by mechanical injection. Temporary regulations were published on April 26, 2005, but postponed by Notice 2005-80.

3. Final regulations related to taxable medical devices under Sec. 4191, as added by Sec. 1405 of the Health Care and Education Reconciliation Act. Proposed regulations were published on February 7, 2012.

4. Final regulations under Sec. 4481 (as amended by the American Jobs Creation Act of 2004) related to electronic filing of highway use tax returns and the proration of tax when vehicles are sold.

5. Final regulations concerning the indoor tanning tax under Sec. 5000B, as added by Sec. 10907 of the ACA. Temporary and proposed regulations were published on June 15, 2010.

6. Notice providing annual deadlines for procedures relating to the fee imposed on covered entities engaged in the business of manufacturing or importing branded prescription drugs under Sec. 9008 of the ACA.

7. Regulations on the annual fee on health insurance providers under Sec. 9010 of the ACA.

Exempt Organizations

1. Revenue Procedures updating grantor and contributor reliance criteria under Secs. 170 and 509.

2. Revenue Procedure to update Revenue Procedure 2011-33 for EO Select Check.

3. Regulations under Sec. 501(r) on requirement for community health needs assessments by charitable hospitals as added by Sec. 9007 of the ACA.

4. Final regulations under Secs. 501(r) and 6033 on additional requirements for charitable hospitals as added by Sec. 9007 of the ACA. Proposed regulations were published on June 26, 2012.

5. Final regulations under Secs. 509 and 4943 regarding the new requirements for supporting organizations (SOs) as added by Sec. 1241 of the Pension Protection Act of 2006. Proposed regulations were published on September 24, 2009.

6. Additional guidance on Sec. 509(a)(3) supporting organizations (SOs).

7. Additional guidance under Secs. 4942 and 4945 regarding reliance standards for making equivalency determinations.

8. Final regulations under Sec. 4944 on program-related investments. Proposed regulations were published on April 19, 2012.

9. Regulations regarding the new excise taxes on donor advised funds and fund management under Sec. 4966 as added by Sec. 1231 of the Pension Protection Act of 2006.

10. Regulations under Sec. 6033 on group returns.

11. Revenue Procedure under Sec. 6033 to update and consolidate all non-regulatory exceptions from filing.

12. Final regulations under Sec. 6104(c). Proposed regulations were published on March 15, 2011.

13. Final regulations under Sec. 7611 relating to church tax inquiries and examinations. Proposed regulations were published on August 5, 2009.

Financial Institutions and Products

1. Regulations under Sec. 446 on notional principal contracts (NPC) relating to the inclusion in income or deduction of a contingent nonperiodic payment and guidance relating to the character of payments made pursuant to an NPC. Proposed regulations were published on February 26, 2004.

2. Regulations revising the RIC asset test examples in Sec. 1.851-5.

3. Revenue Procedure that will modify Revenue Procedure 2011-16 relating to the treatment of distressed debt under Sec. 856.

4. Final regulations addressing when a transfer or assignment of certain derivative contracts does not result in an exchange to the nonassigning counterparty for purposes of Sec. 1.1001-1(a). Temporary and proposed regulations were published on July 22, 2011.

5. Regulations amending Sec. 1.1092(d)-1(d). Proposed regulations were published on January 18, 2001.

6. Guidance addressing the character and timing of hedge gains and losses for purposes of Secs. 1221 and 1.446-4 for hedges of guaranteed living benefits and death benefits provided with regard to variable annuities.

7. Final regulations on the application of Sec. 1256 to certain derivative contracts. Proposed regulations were published on September 16, 2011.

8. Revenue Procedure to determine how to compute the accruals of original issue discount (OID) on pools of revolving cardholder debt held by credit card issuers under Sec. 1272(a)(6). Notice 2011-99 was published on December 12, 2011.

9. Final regulations under Sec. 1273 for determining when a debt instrument is publicly traded. Proposed regulations were published on January 7, 2011.

10. Final regulations amending Sec. 1.1275-7 to provide guidance on Treasury Inflation-Protected Securities (TIPS) issued at a premium. Temporary and proposed regulations were published on December 5, 2011.

11. Final regulations under Sec. 6045 to address basis reporting for options and debt instruments. Proposed regulations were published on November 25, 2011.

12. Regulations on prepaid forward contracts. Notice 2008-02 and Revenue Ruling 2008-01 were published on January 14, 2008.

13. Guidance under the Regulated Investment Company Modernization Act of 2010.

14. Regulations relating to accruals of interest (including discount) on distressed debt. 15. Final regulations that remove any reference to, or requirement of reliance on, "credit ratings" in regulations under the Internal Revenue Code pursuant to Sec. 939A(a) of the Dodd-Frank Wall Street and Consumer Protection Act. Temporary and proposed regulations were published on July 6, 2011.

General Tax Issues

1. Guidance under Sec. 25D regarding credits for residential energy efficient property.

2. Guidance on additional issues under Sec. 36B, as added by Sec. 1401 of the ACA.

3. Regulations under Sec. 41 on the exception from the definition of "qualified research" for internal use software under Sec. 41(d)(4)(E).

4. Regulations under Sec. 41 on whether the gross receipts component of the research credit computation for a controlled group under Sec. 41(f) includes gross receipts from transactions between group members.

5. Guidance under Sec. 42 relating to the application of the design and construction accessibility requirements under the Fair Housing Act.

6. Regulations under Sec. 42 relating to compliance monitoring, including issues identified in Notice 2012-18.

7. Revenue Procedure updating Revenue Procedure 2007-54, which provides relief under Sec. 42 in the case of a presidentially declared disaster.

8. Notice providing relief from certain Sec. 42 requirements following Hurricane Sandy.

9. Guidance concerning the exception under Sec. 42(d)(6) for any federally or State assisted building.

10. Regulations concerning utility allowances under Sec. 42(g)(2)(B)(ii) for sub-metered buildings. Interim guidance was issued in Notice 2009-44, 2009-21 I.R.B. 1037.

11. Final regulations under Sec. 45D that revise and clarify certain rules relating to recapture of the new markets tax credit as well as other issues. Proposed regulations were published August 11, 2008.

12. Regulations under Sec. 45D on new markets non-real estate investments. Proposed regulations and an advance notice of proposed rulemaking were published on June 7, 2011.

13. Guidance concerning the credit for production from advanced nuclear power facilities under Sec. 45J.

14. Guidance on the energy credit under Sec. 48.

15. Guidance on allocation and redistribution of clean coal facility credits under Sec. 48A.

16. Guidance under Sec. 61 regarding the application of the general welfare exclusion to benefits provided to Indian tribal members by Indian tribal governments.

17. Notice under Sec. 61 regarding payments of Indian tribal trust settlement proceeds.

18. Notice under Sec. 61 regarding employer sponsored leave-based donation programs to aid victims of Hurricane Sandy.

19. Final regulations under Secs. 108 and 7701 concerning the bankruptcy and insolvency rules and disregarded entities. Proposed regulations were published on April 13, 2011.

20. Final regulations under Sec. 108(i) for partnerships and S corporations. Proposed and temporary regulations were published on August 13, 2010.

21. Revenue Procedure under Sec. 108(c) on the definition of "secured by real property."

22. Regulations under Sec. 152 regarding the definition of dependent.

23. Final regulations under Secs. 162 and 262 regarding the deductibility of expenses for lodging not incurred in traveling away from home. Proposed regulations were published on April 25, 2012.

24. Guidance under Sec. 163(h) regarding the mortgage interest limitations.

25. Final regulations under Sec. 170 regarding charitable contributions. Proposed regulations were published on August 7, 2008.

26. Notice under Sec. 170 regarding charitable contributions to disregarded entities.

27. Regulations under Sec. 174 concerning inventory property.

28. Regulations under Sec. 199 including amendments by the Tax Extenders and Alternative Minimum Relief Act of 2008.

29. Regulations under Sec. 199 relating to computer software.

30. Regulations under Sec. 213 regarding medical and dental expenses.

31. Regulations on delay rentals under Secs. 263A and 612.

32. Final regulations under Sec. 274 regarding the entertainment use of company aircraft. Proposed regulations were published on June 15, 2007.

33. Regulations under Sec. 274(n) regarding reimbursement and other expense allowance arrangements, including employee leasing arrangements.

34. Regulations under Sec. 280A regarding deductions for expenses attributable to the business use of homes and rental of vacation homes.

36. Guidance updating existing regulations regarding basis to include references to Sec. 1022 as appropriate.

37. Regulations under Sec. 1411, as added by Sec. 1402 of the Health Care and Education Reconciliation Act, regarding net investment income tax.

38. Guidance under Sec. 5000A, as added by Sec. 1501(b) of the ACA, concerning the penalty imposed for failure to maintain minimum essential coverage.

39. Regulations under Sec. 6055, as added by Sec. 1502 of the ACA, regarding reporting of health insurance and other minimum essential coverage.

40. Final regulations under Sec. 7701 regarding Series LLCs and cell companies. Proposed regulations were published on September 14, 2010.

41. Regulations under Sec. 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government.

42. Guidance regarding the scope and application of the rescission doctrine.

Gifts and Estates and Trusts

1. Final regulations under Sec. 67 regarding miscellaneous itemized deductions of a trust or estate. Proposed regulations were published on September 7, 2011.

2. Guidance concerning adjustments to sample charitable remainder trust forms under Sec. 664.

3. Guidance concerning private trust companies under Secs. 671, 2036, 2038, 2041, 2042, 2511, and 2601.

4. Regulations under Sec. 1014 regarding uniform basis of charitable remainder trusts.

5. Final regulations under Sec. 2032(a) regarding imposition of restrictions on estate assets during the six month valuation period. Proposed regulations were published on November 18, 2011.

6. Guidance under Sec. 2053 regarding personal guarantees and the application of present value concepts in determining the deductible amount of expenses and claims against the estate.

7. Regulations under Sec. 2642 regarding the allocation of GST exemption to a pour-over trust at the end of an ETIP.

8. Final regulations under Sec. 2642(g) regarding extensions of time to make allocations of the generation-skipping transfer tax exemption. Proposed regulations were published on April 17, 2008.

9. Regulations under Sec. 2704 regarding restrictions on the liquidation of an interest in certain corporations and partnerships.

10. Guidance under Sec. 2801 regarding the tax imposed on U.S. citizens and residents who receive gifts or bequests from certain expatriates.

Insurance Companies and Products

1. Final regulations under Sec. 72 on the exchange of property for an annuity contract. Proposed regulations were published on October 18, 2006.

2. Guidance on annuity contracts with a long-term care insurance rider under Secs. 72 and 7702B.

3. Revenue Ruling under Sec. 801 addressing the application of Revenue Ruling 2005-40 or Revenue Ruling 92-93 to health insurance arrangements that are sponsored by a single employer.

4. Guidance to clarify which table to use for Sec. 807(d)(2) purposes when there is more than one applicable table in the 2001 CSO mortality table.

5. Notice clarifying whether deficiency reserves should be taken into account in computing statutory reserves under Sec. 807(d)(6).

6. Revenue Ruling on the determination of the company's share and policyholder's share of the net investment income of a life insurance company under Sec. 812.

7. Guidance clarifying whether the Conditional Tail Expectation Amount computed under AG 43 should be taken into account for purposes of the Reserve Ratio Test under Sec. 816(a) and the Statutory Reserve Cap under Sec. 807(d)(6).

8. Regulations under Sec. 833 to establish the method to be used by Blue Cross Blue Shield entities in determining the medical loss ratio required by that section.

9. Guidance on exchanges under Sec. 1035 of annuities for long-term care insurance contracts.

10. Regulations under Sec. 7702 defining cash surrender value.

International Issues

A. Subpart F/Deferral

1. Guidance under Sec. 954(c), including guidance related to the treatment of transactions involving commodities and nonfunctional currency.

2. Guidance under Sec. 954 regarding foreign base company sales income and services income.

3. Regulations under Sec. 956 regarding the treatment of loans to foreign partnerships and related issues.

4. Final regulations under Sec. 959 on previously taxed earnings and profits. Proposed regulations were published on August 29, 2006.

5. Final regulations under Sec. 964 on accounting method elections. Proposed regulations were published on November 3, 2011.

6. Guidance under Secs. 1297 and 1298 on passive foreign investment companies.

B. Inbound Transactions

1. Guidance under Sec. 864 implementing Revenue Ruling 91-32 relating to sales of certain partnership interests.

2. Regulations under Sec. 871(m), added by the Hiring Incentives to Restore Employment Act (HIRE Act) of 2010, on dividend equivalent payments. Temporary and proposed regulations were published on January 23, 2012.

3. Regulations under Sec. 882 regarding insurance companies.

4. Regulations under Sec. 892. Proposed and temporary regulations were published on November 3, 2011.

5. Regulations under Sec. 1441 on withholding in connection with certain live events.

6. Revenue Procedure under Sec. 1441 updating Revenue Procedure 89-47 on central withholding agreements.

7. Final regulations under Sec. 1.6038A-2T regarding filing requirements on Form 5472. Temporary and proposed regulations were published on June 10, 2011.

8. Proposed regulations under Sec. 6038C on information with respect to foreign corporations engaged in a U.S. trade or business.

C. Outbound Transactions

1. Guidance under Sec. 367, including final regulations under Sec. 367(a)(5) regarding outbound asset reorganizations. Proposed regulations were published on August 20, 2008.

2. Regulations under Sec. 367(d) regarding transfers of intangible property to foreign corporations.

3. Guidance under Sec. 6038B, including regulations on the failure to file gain recognition agreements and other required filings.

4. Final regulations under Sec. 7874 regarding substantial business activities. Temporary and proposed regulations were published on June 12, 2012.

5. Regulations under Sec. 7874 implementing Notice 2009-78 regarding surrogate foreign corporations.

D. Foreign Tax Credits

1. Guidance under Sec. 901, including final regulations on noncompulsory payments. Temporary and proposed regulations were published on July 18, 2011.

2. Guidance under Sec. 901(m), added by the Education Jobs and Medicaid Assistance Act of 2010, on covered asset acquisitions.

3. Final regulations under Sec. 904, including regarding overall foreign losses. Proposed regulations were published on June 25, 2012.

4. Regulations under Sec. 904(d)(6), added by the Education Jobs and Medicaid Assistance Act of 2010, on the separate application of the foreign tax credit limitation to income resourced under an income tax treaty. 5. Guidance under Sec. 905, including final regulations under Sec. 905(c) on foreign tax redeterminations. Temporary and proposed regulations were published on November 7, 2007.

6. Final regulations under Sec. 909 on foreign tax credit splitting events. Temporary and proposed regulations were published on February 14, 2012.

7. Guidance under Sec. 960(c), added by the Education Jobs and Medicaid Assistance Act of 2010, on the amount of foreign taxes deemed paid with respect to Sec. 956 inclusions.

E. Transfer Pricing

1. Guidance under Sec. 482, including final regulations regarding cost sharing arrangements. Temporary and proposed regulations were published on December 23, 2011.

2. Regulations under Sec. 482 on global dealing operations. Proposed regulations were published on March 6, 1998.

3. Annual Report on the Advance Pricing Agreement Program.

4. Revenue Procedure updating Revenue Procedure 2006-9, as amended by Revenue Procedure 2008-31, on the Advance Pricing and Mutual Agreement Program.

F. Sourcing and Expense Allocation

1. Guidance under Sec. 861, including regulations under § 861 regarding the allocation and apportionment of interest expense. Temporary and proposed regulations were published on January 17, 2012.

2. Regulations under Sec. 861 on the source of event basis compensation. Proposed regulations were published on October 17, 2007.

3. Regulations under Secs. 861, 862, and 863(a) on the source of income, including regulations on the source of income from intangible property.

G. Treaties

1. Guidance under Sec. 894 on issues under income tax treaties, including beneficial ownership.

2. Revenue Procedure updating Revenue Procedure 2006-54 on procedures for taxpayers requesting Competent Authority assistance.

3. Miscellaneous Announcements, e.g., on agreements under Mutual Agreement Procedures (MAP) and of Reciprocal Exemption Agreements.

H. Other

1. Final regulations under Sec. 304 preventing the use of related corporations to avoid Sec. 304. Temporary and proposed regulations were published on December 29, 2009.

2. Notice under Sec. 877A supplementing Notice 2009-85.

3. Regulations under Sec. 937(a) concerning the "presence test" for bona fide residency in a U.S. Territory.

4. Final regulations under Sec. 987. Proposed regulations were published on September 7, 2006.

5. Guidance on Sec. 988 transactions, including hedging transactions.

6. Regulations under Sec. 1356 concerning core, secondary, and incidental activities under the tonnage tax.

7. Guidance under Chapter 3 (Secs. 1441-1446) and Chapter 4 (Secs. 1471-1474), added by the HIRE Act of 2010, including final regulations under Chapter 4. Proposed regulations were published on February 15, 2012. (Announcement Regarding Timelines And Other Requirements PUBLISHED 11/19/12 in IRB 2012-47 as ANN. 2012-42 RELEASED 10/24/12).

8. Guidance under Sec. 3402 on Military Spouses Residency Relief Act in relation to the U.S. territories.

9. Guidance under Sec. 6038D, added by the HIRE Act of 2010, including final regulations on foreign financial asset reporting. Temporary and proposed regulations were published on December 19, 2011.

10. Final regulations under Sec. 6039E concerning passport information. Proposed regulations were published on January 26, 2012.

11. Regulations under Secs. 6048 and 6677 on foreign trust reporting.

12. Guidance under Sec. 7701 regarding entity classification.

13. Regulations on the excise tax under Sec. 5000C on certain foreign procurement payments by the Federal government.

14. Guidance under Sec. 6050W to certain payment settlement entities regarding the circumstances under which the return of information is required with respect to a payment to an offshore account. (PUBLISHED 11/05/12 in IRB 2012-45 as NOT. 2012-2 RELEASED 10/18/12).

Partnerships

1. Regulations under Sec. 108(e)(7).

2. Regulations under Sec. 1.337(d)-3 relating to partnership transactions involving a corporate partner's stock or other equity interests.

3. Final regulations under Sec. 469(h)(2) concerning limited partners and material participation. Proposed regulations were published on November 28, 2011.

4. Regulations concerning the fractions rule under Sec. 514(c)(9).

5. Regulations under Secs. 704, 734, 743, and 755 arising from the American Jobs Creation Act of 2004, P.L. 108-357, 118 Stat. 1418, regarding the disallowance of certain partnership loss transfers and no reduction of basis in stock held by a partnership in a corporate partner. Interim guidance was issued as Notice 2005-32.

6. Final regulations under Sec. 706(d) regarding the determination of a distributive share when a partner's interest changes. Proposed regulations were published on April 14, 2009.

7. Regulations under Sec. 706(d) regarding the determination of a distributive share of any allocable cash basis items and certain other items when a partner's interest changes.

8. Regulations under Sec. 707 relating to disguised sales of property.

9. Regulations under Secs. 709 and 195 on organizational and start-up expenses of a partnership after a technical termination.

10. Regulations under Sec. 721 regarding the tax treatment of noncompensatory options and convertible instruments issued by a partnership. Proposed regulations were published on January 22, 2003.

11. Regulations under Sec. 751(b) on unrealized receivables and inventory.

12. Regulations under Sec. 752 regarding related person rules.

13. Final regulations regarding the de minimis partner rule. Proposed regulations were published on October 25, 2011.

Subchapter S Corporations

1. Guidance under Secs. 1362 and 301.9100 regarding elections of S corporations.

2. Guidance under Sec. 1366.

3. Final regulations under Sec. 1367 regarding S corporations and back-to-back loans. Proposed regulations were published on June 12, 2012.

Tax Accounting

1. Notice under Secs. 167 and 1031 requesting comments on whether property held simultaneously for sale and for lease (also known as "dual-use property") is eligible for depreciation deductions and/or like-kind exchange treatment.

2. Revenue Procedure under Sec. 168(k)(4), as added by Sec. 401(c) of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, regarding the election to accelerate carryover AMT credits in lieu of claiming bonus depreciation.

3. Regulations under Sec. 174 regarding procedures for adopting or changing methods of accounting for research and experimental expenditures.

4. Guidance under Sec. 179(f), as added by § 2021 of the Small Business Jobs Act of 2010, regarding qualified real property.

5. Final regulations under Sec. 181 regarding deductions for the costs of producing qualified film and television productions to reflect changes made by the Tax Extenders and Alternative Minimum Tax Relief Act of 2008. Temporary and proposed regulations were published on October 19, 2011.

6. Regulations under Sec. 263A regarding the inclusion of negative amounts in additional Sec. 263A costs. (PUBLISHED 09/05/12 in FR AS REG-126770-06.)

7. Final regulations under Secs. 263A and 471 regarding sales-based royalties and sales-based vendor allowances. Proposed regulations were published on December 17, 2010.

8. Regulations under Secs. 263A and 702 regarding the treatment of excess depletion.

9. Final regulations under Sec. 263(a) regarding the deduction and capitalization of expenditures related to tangible property. Proposed and temporary regulations were published December 27, 2011.

10. Revenue Procedure under Sec. 263(a) regarding the capitalization of cable network property.

11. Revenue Procedure under Sec. 263(a) regarding the capitalization of electric generation property.

12. Revenue Procedure under Sec. 263(a) regarding the capitalization of natural gas transmission and distribution property.

13. Guidance regarding the application of Sec. 1.267(b)-1(b) to partners and partnerships.

14. Revenue Procedure under Sec. 446 updating Rev. Proc. 97-27, providing procedures and rules for non-automatic changes in method of accounting.

15. Revenue Procedure under Sec. 446 modifying Rev. Proc. 2011-14 and Rev. Proc. 9727 for rules relating to certain changes in methods of accounting regarding transactions to which Sec. 381 applies, a change in method of accounting described in Rev. Proc. 2011-43 for taxpayers in the business of transporting, delivering or selling electricity, and a change in method of accounting for amounts paid or incurred for the installation of energy efficient commercial building property under Sec. 179D. (PUBLISHED 10/09/12 in IRB 2012-41 as REV. PROC. 2012-39 RELEASED 09/04/12.)

16. Regulations under Sec. 453 addressing certain annuity contracts received in exchange for property.

17. Guidance under Sec. 453B regarding nonrecognition of gain or loss on the disposition of certain installment obligations.

18. Regulations under Sec. 460 addressing the application of the lookback interest rules to certain pass-through entities with tax-exempt owners.

19. Regulations under Sec. 460 regarding home construction contracts and rules for certain changes in method of accounting for long-term contracts.

20. Final regulations amending Sec. 1.471-8 regarding the treatment of vendor allowances under the retail inventory method. Proposed regulations were published on October 7, 2011.

21. Regulations under Sec. 472 regarding the carryover of last-in, first-out layers following a Sec. 351 or Sec. 721 transaction.

222. Regulations amending Sec. 1.472-8 regarding the inventory price index computation (IPIC) method.

Tax Administration

1. Regulations on Sec. 3406 backup withholding for payment card transactions. Proposed regulations were published July 7, 2007, but were superseded by final regulations under Secs.3406 and 6050W that were published August 16, 2010.

2. Regulations under Secs. 3505 and 6503 concerning the statute of limitations for lender liability cases.

3. Revenue Procedure under Secs. 6011, 6061, and 6302 regarding third-party payer issues and reporting agents. (PUBLISHED 08/20/12 in IRB 2012-34 as REV. PROC. 2012-32 RELEASED 07/26/12, PUBLISHED 08/20/12 in IRB 2012-34 as REV. PROC. 2012-33 RELEASED 07/26/12.

4. Guidance under Sec. 6015 regarding relief from joint and several liability.

5. Guidance under Sec. 6041 relating to Forms W-2G.

6. Notice under Sec. 6050P regarding information reporting pertaining to cancellation of debt. (TO BE PUBLISHED 12/27/12 in IRB 2012-52 as NOT 2012-65 RELEASED 11/09/12).

7. Revenue Procedure under Sec. 6050P concerning reporting of cancellation of indebtedness income from participation in the Principal Reduction Alternative of the Home Affordable Modification Program.

8. Regulations under Sec. 6050W, as added by Sec. 3091 of the Housing Assistance Act of 2008, regarding information reporting on payment card and third-party payment transactions.

9. Final regulations under Sec. 6103(c) relating to consents to disclose returns and return information. Proposed regulations were published March 18, 2011.

10. Final regulations under Sec. 6103(l)(21), as added by Sec. 1414 of the ACA, pertaining to disclosure of return information to the Department of Health and Human Services. Proposed regulations were published April 30, 2012. 11. Final regulations under Sec. 6109 regarding PTINs. Proposed regulations were published February 15, 2012.

12. Final regulations under Sec. 6109 requiring updating of entity information. Proposed regulations were published March 14, 2012.

13. Revenue procedure under Sec. 6110 updating Revenue Procedure 95-15. (PUBLISHED 08/13/12 in IRB 2012-33 as REV. PROC. 2012-31 RELEASED 07/17/12).

14. Regulations under Sec. 6166 regarding the furnishing of security in connection with an election to pay the estate tax in installments.

15. Regulations under Sec. 6231 regarding the special enforcement exception to the application of the Tax Equity and Fiscal Responsibility Act (TEFRA) partnership procedures. Proposed regulations were published on February 13, 2009.

16. Final regulations under Sec. 6402 concerning where to file a claim for refund. Proposed regulations were published June 10, 2011.

17. Final regulations under Sec. 6501(c)(10) regarding the extension of the statute of limitations for assessment relating to failures to report required information concerning listed transactions, necessitated by sec. 814 of the American Jobs Creation Act of 2004. Proposed regulations were published on October 7, 2009.

18. Regulations under Sec. 6611 regarding interest on overpayments by tax exempt organizations.

19. Final regulations under Sec. 6654(d) regarding reduced 2009 estimated tax payments for individuals with small business income. Temporary and proposed regulations were published February 26, 2010.

20. Regulations under Secs. 6662, 6662A, and 6664 regarding accuracy-related penalties relating to understatements. Interim guidance was issued as Notice 2005-12.

21. Revenue Procedure under Sec. 6664 updating Revenue Procedure 94-69 regarding qualified amended returns filed by coordinated industry case (CIC) taxpayers.

22. Regulations under Sec. 6676 regarding the penalty for erroneous claims for refund as added by § 8247 of the Small Business and Work Opportunity Tax Act of 2007.

23. Regulations under Sec. 6695A, as added by § 1219 of the Pension Protection Act of 2006, regarding the penalty applicable to appraisers.

24. Revenue Procedure under Sec. 6702 relating to reduction of penalties for frivolous tax submissions. (TO BE PUBLISHED 12/03/12 in IRB 2012-49 as REV. PROC. 2012-43 RELEASED 11/05/12).

25. Final regulations under Sec. 6707 regarding the penalty for failure to furnish information required by § 6111. Proposed regulations were published on December 22, 2008.

26. Regulations under Sec. 6707A, as amended by sec. 2041(a) of the Small Business Jobs Act of 2010, regarding the penalty for failure to disclose reportable transactions.

27. Final regulations under Sec/ 6708 regarding the penalty for failure to make a list of advisees available as required by Sec. 6112. Proposed regulations were published on December 19, 2008.

28. Announcement under Sec. 7123 pertaining to fast track programs. (PUBLISHED 09/04/12 in IRB 2012-36 as ANN. 2012-34 RELEASED 08/31/12).

29. Guidance under Sec. 7216 regarding the disclosure and use of tax return information by tax return preparers. Prior guidance was issued as Revenue Rulings 2010-4 and 2010-5 on January 21, 2010. Temporary regulations were published on December 29, 2009.

30. Final regulations under Sec. 7430 regarding attorney fees. Proposed regulations were published November 25, 2009.

31. Revenue Procedure under Sec. 7430 regarding awards of attorney fees.

32. Revenue Procedure under Sec. 7502 pertaining to private delivery services. Final regulations were published August 23, 2011.

33. Regulations under Sec. 7623, as amended by sec. 406 of the Tax Relief and Healthcare Act of 2006, regarding whistleblower awards and the operation of the Whistleblower Office.

34. Guidance under Secs. 7701(o) and 6662(b)(6) regarding codification of the economic substance doctrine by sec. 1409 of the Health Care and Education Reconciliation Act of 2010. Prior guidance was issued as Notice 2010-62.

35. Guidance under Sec. 301.9100.

36. Regulations revising Circular 230 regarding practice before the IRS. (PUBLISHED 09/17/12 in FR as REG-138367-06.)

37. Revenue Procedure revising Revenue Procedure 94-22. (PUBLISHED 09/10/12 in IRB 2012-37 as REV. PROC. 2012-35 RELEASED 08/31/12).

38. Regulations relating to Taxpayer Identification Numbers on payee statements.

39. Regulations updating user fees for offers in compromise and installment agreements.

Tax-Exempt Bonds

1. Final regulations on public approval requirements for private activity bonds under Sec. 147(f). Proposed regulations were published on September 9, 2008.

2. Regulations on arbitrage investment restrictions under Sec. 148.

3. Regulations on rebate overpayment under Sec. 148.

4. Regulations on bond reissuance under Sec. 150. Notice 2008-41 was published on April 14, 2008 and was supplemented by Notice 2008-88 and Notice 2010-7.

5. Notice on tribal economic development bond allocations under Sec. 7871.

APPENDIX -- Regularly Scheduled Publications

Note. Monthly recurring items (e.g., AFRs) omitted.

JULY 2012

--Revenue Ruling providing the average annual effective interest rates charged by each Farm Credit Bank District.

AUGUST 2012

--Guidance providing the inflation adjustment factor to be used in determining the enhanced oil recovery credit under Sec. 43 for tax years beginning in the calendar year.

--Guidance providing the applicable percentage to be used in determining percentage depletion for marginal properties under Sec. 613A for the calendar year.

--Revenue Procedure providing the domestic asset/liability percentages and the domestic investment yield percentages for taxable years beginning after December 31, 2009, for foreign companies conducting insurance business in the United States.

SEPTEMBER 2012

--Revenue Ruling under Sec. 6621 regarding the applicable interest rates for overpayments and underpayments of tax for the period October through December 2012.

--Guidance under Sec. 274 regarding the deemed substantiation of travel expenses using per diem rates.

--Update of Notice 2004-83 to add approved applicants for designated private delivery service status under Sec. 7502(f). Will be published only if any new applicants are approved.

--Notice identifying the counties that experienced exceptional, extreme, or severe drought during the preceding 12-month period ending August 31, 2012, for purposes of determining whether the replacement period within which to replace livestock sold on account of drought is extended under Sec. 1033(e)(2)(B) and Notice 2006-82.

--Revenue Ruling setting forth the terminal charge and the standard industry fare level (SIFL) cents-per-mile rates for the second half of 2012 for use in valuing personal flights on employer-provided aircraft.

OCTOBER 2012

--Revenue Procedure under Sec. 1 and other sections of the Code regarding the inflation adjusted items for 2013.

--Revenue Procedure providing the loss payment patterns and discount factors for the 2012 accident year to be used for computing unpaid losses under Sec. 846.

--Revenue Procedure providing the salvage discount factors for the 2012 accident year to be used for computing discounted estimated salvage recoverable under Sec. 832.

--Update of Revenue Procedure 2005-27 listing the tax deadlines that may be extended by the Commissioner under Sec. 7508A in the event of a Presidentially declared disaster or terrorist attack. Will be published only if there are any updates.

--Guidance providing the amounts of unused housing credit carryover allocated to qualified states under Sec. 42(h)(3)(D) for the calendar year.

NOVEMBER 2012

--Revenue Ruling providing the "base period T-Bill rate" as required by Sec. 995(f)(4).

--Revenue Ruling setting forth covered compensation tables for the 2012 calendar year for determining contributions to defined benefit plans and permitted disparity.

--Update of Revenue Procedure 2006-48 regarding adequate disclosure for purposes of the Sec. 6662 substantial understatement penalty and the Sec. 6694 preparer penalty. Will be published only if there are any updates.

--News release setting forth cost-of living adjustments effective January 1, 2013, applicable to the dollar limits on benefits under qualified defined benefit pension plans and other provisions affecting certain plans of deferred compensation.

--Federal Register notice on Railroad Retirement Tier 2 tax rate.

--Guidance under Sec. 274 regarding the 2013 optional standard mileage rates.

DECEMBER 2012

--Revenue Ruling under Sec. 6621 regarding the applicable interest rates for overpayments and underpayments of tax for the period January through March 2012.

JANUARY 2013

--Revenue Procedure updating the procedures for issuing private letter rulings, determination letters, and information letters on specific issues under the jurisdiction of the Chief Counsel.

--Revenue Procedure updating the procedures for furnishing technical advice, including technical expedited advice, to certain IRS offices, in the areas under the jurisdiction of the Chief Counsel.

--Revenue Procedure updating the previously published list of "no-rule" issues under the jurisdiction of certain Associates Chief Counsel other than the Associate Chief Counsel (International) on which advance letter rulings or determination letters will not be issued.

--Revenue Procedure updating the previously published list of "no-rule" issues under the jurisdiction of the Associate Chief Counsel (International) on which advance letter ruling or determination letters will not be issued.

--Revenue Procedure updating procedures for furnishing letter rulings, general information letters, etc. in employee plans and exempt organization matters relating to sections of the Code under the jurisdiction of the Office of the Commissioner, Tax Exempt and Government Entities Division.

--Revenue Procedure updating procedures for furnishing technical advice in employee plans and exempt organization matters under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division.

--Revenue Ruling providing the dollar amounts, increased by the 2013 inflation adjustment, for Sec. 1274A.

--Revenue Procedure under Sec. 280F providing limitations on depreciation deductions for owners of passenger automobiles first placed in service during the calendar year and amounts to be included in income by lessees of passenger automobiles first leased during the calendar year.

--Revenue Procedure updating procedures for issuing determination letters on the qualified status of employee plans under Secs. 401(a), 403(a), 409, and 4975.

--Revenue Procedure updating procedures for issuing determination letters and rulings on the exempt status of organizations under Secs. 501 and 521.

--Revenue Procedure updating procedures for issuing determination letters and rulings on public charity/private foundation classification.

--Revenue Procedure updating the user fee program as it pertains to requests for letter rulings, determination letters, etc. in employee plans and exempt organizations matters under the jurisdiction of the Office of the Commissioner, Tax Exempt and Government Entities Division.

--Revenue Procedure under Sec. 143 regarding average area purchase price.

--Revenue Procedure providing the maximum allowable value for use of the fleet-average value and vehicle-cents-per-mile rules to value employer-provided automobiles first made available to employees for personal use in the calendar year.

--Revenue Procedure providing the annual update of Domestic No-Rule Areas.

--Revenue Ruling setting forth the prevailing state assumed interest rates provided for the determination of reserves under Sec. 807 for contracts issued in 2012 and 2013.

FEBRUARY 2013

--Notice under Sec. 911 on the Housing Cost Amount for 2013.

MARCH 2013

--Guidance providing the 2013 calendar year resident population estimates used in determining the state housing credit ceiling under Sec. 42(h) and the private activity bond volume cap under Sec. 146.

--Revenue Ruling under Sec. 6621 regarding the applicable interest rates for overpayments and underpayments of tax for the period April through June 2013.

--Revenue Ruling setting forth the terminal charge and the standard industry fare level (SIFL) cents-per-mile rates for the first half of 2013 for use in valuing personal flights on employer-provided aircraft.

APRIL 2013

--Guidance providing the inflation adjustment factor, nonconventional fuel source credit, and reference price for the calendar year that determines the availability of the credit for producing fuel from a nonconventional source under Sec. 45K.

--Revenue Procedure providing a current list of countries and the dates those countries are subject to the Sec. 911(d)(4) waiver and guidance to individuals who fail to meet the eligibility requirements of Sec. 911(d)(1) because of adverse conditions in a foreign country.

--Guidance providing the calendar year inflation adjustment factor and reference prices for the renewable electricity production credit under Sec. 45.

--Guidance providing the calendar year inflation adjustment factor to be used in determining the credit for carbon dioxide sequestration under Sec. 45Q.

MAY 2013

--Revenue Procedure providing guidance for use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit certificates in determining the housing cost/income ratio under Sec. 143.

--Revenue Procedure under Sec. 223 regarding the inflation adjusted items for 2014.

JUNE 2013

--Revenue Ruling under Sec. 6621 regarding the applicable interest rates for overpayments and underpayments of tax for the period July through September 2013.

--Last Update 11/23/12