Small Business Taxes & Management

Special Report


IRS Priority Guidance Plan 2013-2014

 

Small Business Taxes & ManagementTM--Copyright 2013, A/N Group, Inc.

 

Note. This text below covers planned publications from February 1, 2014 through June 30, 2014.

 

 

Consolidated Returns

1. Final regulations regarding the application of Sec. 172(h) to a consolidated group. Proposed regulations were published on September 17, 2012.

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 a consolidated group. Proposed regulations were published on May 30, 2012.

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

 

 

Corporations and Their Shareholders

1. 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.

2. 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.

3. 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.

4. Guidance regarding when a transfer by a person to a corporation and a transfer by that corporation to that person, ostensibly in two separate transactions, should be respected as two separate transactions for Federal income tax purposes.

5. Guidance regarding whether a corporation is a "controlled corporation" within the meaning of Sec. 355 if, in anticipation of the distribution of its stock, the distributing corporation acquires or retains putative control of the controlled corporation through the use of classes of shares having different voting powers.

6. Guidance regarding the application of Secs. 355 and 361 to a distributing corporation's use of its controlled corporation's stock or securities to retire its putative debt issued in anticipation of the distribution of the stock of the controlled corporation.

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

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

9. Final regulations regarding Sec. 358 as applied to all-cash D transactions. Temporary and proposed regulations were published on November 21, 2011.

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

11. Final regulations under Sec. 368 on measuring continuity of interest in corporate reorganizations. Proposed regulations were published on December 19, 2011.

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

 

Employee Benefits

 

A. Retirement Benefits

1. Regulations updating the rules applicable to ESOPs.

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

3. 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, and in Notice 2007-69.

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

5. Revenue Procedure under Secs. 401(a) and 403(a) updating Revenue Procedure 2007-44 for determination letters for individually designed and pre-approved plans.

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

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. Guidance under Sec. 404 on deductions for employer contributions to qualified plans.

11. Guidance on rules applicable to IRAs under Secs. 408 and 408A. 12. Guidance updating regulations for service credit and vesting under Sec. 411.

13. Regulations under Sec. 411(a)(11). Proposed regulations were published on October 9, 2008.

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

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

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

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

21. 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.

22. 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.

23. 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.

24. 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.

25. 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.

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

27. Guidance concerning Sec. 4975.

28. 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.

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

30. 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.

31. Guidance facilitating rollovers into retirement plans.

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

33. Guidance on certain issues related to multiple employer plans.

34. Revenue Procedure amending Revenue Procedure 2013-12 relating to Employee Plans Compliance Resolution System to provide guidance with regard to certain corrections.

 

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

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

2. Regulations under Sec. 86 regarding rules for lump-sum elections.

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

4. 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 2012-38.

5. 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 on June 24, 2011.

6. Final regulations under Sec. 162(m)(6) as added by Sec. 9014 of the ACA. Proposed regulations were published on April 2, 2013.

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

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

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

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

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

12. 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.

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

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

15. Final regulations under Secs. 3127, 3121(b)(3)(A), and 3306(c)(5) making certain FICA exceptions available for disregarded entities. Temporary regulations were published on November 12, 2011.

16. Final regulations under Sec. 3504 designating certain parties that file employment tax returns under their EINs for their clients' workers as persons required to perform acts of employers. Proposed regulations were published on January 29, 2013.

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

18. Final regulations on shared responsibility for employers regarding health coverage under Sec. 4980H, as added by Sec. 1513 of the ACA. Proposed regulations were published on January 2, 2013.

19. 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. Guidance on the application of the air transportation excise tax under Sec. 4261 to aircraft management fees.

4. Guidance under Sec. 4261(e)(3)(C) regarding the application of the domestic air transportation excise tax under Sec. 4261 to the purchase of mileage awards.

5. 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.

6. Final regulations on the annual fee on branded prescription drug manufacturers and importers under Sec. 9008 of the ACA. Temporary and proposed regulations were published on August 8, 2011.

 

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. Final regulations under Secs. 501(r) and 6033 on additional requirements for charitable hospitals as added by § 9007 of the ACA. Proposed regulations were published on June 26, 2012 and April 5, 2013.

4. Guidance under Sec. 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners.

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

6. Guidance regarding the new excise taxes on donor advised funds and fund management as added by Sec. 1231 of the Pension Protection Act of 2006.

7. Guidance under Sec. 6033 on returns of exempt organizations.

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

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

 

Financial Products and Institutions

1. Guidance under Sec. 166 on the conclusive presumption of worthlessness for bad debts. Notice 2013-35, which requested comments on the existing rules, was published on June 10, 2013.

2. Final regulations providing guidance under Sec. 171 for a bond premium carryforward on certain debt instruments, such as a Treasury bill acquired at a premium. Temporary and proposed regulations were published on January 4, 2013.

3. Guidance on the method used to determine the adjusted applicable Federal rate for purposes of Secs. 382 and 1288. Notice 2013-4 was published on February 25, 2013.

4. 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.

5. Notice updating Notice 97-64 to reflect changes to Sec. 852 by the Regulated Investment Company Modernization Act of 2010.

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

7. 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.

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

9. Final regulations providing guidance under Sec. 6049 for the reporting of premium. Temporary and proposed regulations were published on April 18, 2013.

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

11. Regulations relating to accruals of interest (including discount) on distressed debt.

 

General Tax Issues

1. Regulations under Sec. 36B, as added by sec. 1401 of the ACA, regarding minimum value of eligible employer-sponsored coverage and other provisions relating to the health insurance premium tax credit. Proposed regulations were published on May 3, 2013.

2. Final regulations under Sec. 36B, as added by sec. 1401 of the ACA, regarding information reporting by Affordable Insurance Exchanges. Proposed regulations were published on July 2, 2013.

3. Regulations regarding the election of the alternative simplified credit under Sec. 41(c)(5).

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

5. Regulations on the allocation of the research credit to corporations and trades or businesses under common control for purposes of Sec. 41(f)(1).

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

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

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

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

10. Final regulations concerning utility allowances under Sec. 42(g)(2)(B)(ii) for sub-metered buildings. Proposed regulations were published on August 7, 2012.

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. Guidance on the energy credit under Sec. 48.

13. Revenue Procedure under Sec. 61 regarding the application of the general welfare exclusion to benefits provided to Indian tribal members by Indian tribal governments.

14. Revenue Ruling under Sec. 108 regarding the application of the qualified real property business indebtedness exclusion for real estate developers.

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

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

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

18. 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.

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

20. Guidance under Sec. 165 on determining wagering gains and losses.

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

22. Regulations under Sec. 170(f)(8) regarding donee substantiation of charitable contributions.

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

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

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

26. Regulations on delay rentals under Sec. 263A and 612.

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

28. Guidance clarifying whether the business use of an aircraft by a lessee that is a five percent owner or related party of the lessor of the aircraft is qualified business use for purposes of Sec. 280F.

29. Regulations under Sec. 1012 regarding basis rules for stock and debt.

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

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

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

 

Gifts, 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. Revenue Procedure under Sec. 2010(c) regarding the validity of a QTIP election on an estate tax return filed only to elect portability.

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

7. 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.

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

9. 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.

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

11. 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. 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.

6. 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).

7. Final 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. Proposed regulations were published on May 13, 2013.

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

9. 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 on the treatment of upfront payments on swaps under Sec. 956. Temporary and proposed regulations were published on May 11, 2012.

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

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

 

B. Inbound Transactions

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

2. Regulations under Sec. 882 regarding insurance companies.

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

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

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

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

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

 

C. Outbound Transactions

1. Final regulations and other guidance under Sec. 367. Final, temporary, and proposed regulations were published on March 19, 2013.

2. Regulations under Sec. 367(d) regarding transfers of intangible property to foreign corporations, including temporary regulations to implement Notice 2012-39.

3. Final regulations and other guidance under Sec. 6038B, including regulations on the failure to file gain recognition agreements and other required filings. Proposed regulations were published on January 31, 2013.

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

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

3. 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.

4. 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.

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

E. Transfer Pricing

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

2. Annual Report on the Advance Pricing 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 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 the application of various treaty provisions to payments through hybrid entities.

 

H. Other

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

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

3. Guidance on Sec. 988 transactions, including hedging transactions. Temporary and proposed regulations were published on September 6, 2012.

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

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

6. 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.

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

8. Guidance under Secs. 6039F, 6048 and 6677 on information reporting related to foreign trusts and foreign gifts.

9. Guidance under Sec. 7701 relating to classification of certain foreign business entities as per se corporations.

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

 

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 Sec. 704 regarding a substitute de minimis rule.

6. Regulations on forward and reverse allocations under Sec. 704(c).

7. Regulations to update the securities partnership aggregation rules under Sec. 704(c).

8. Guidance under Secs. 704, 707, and 721 on management fee waivers.

9. Regulations under Sec. 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.

10. 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.

11. 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.

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

13. Guidance relating to Sec. 743(b) and contingent liabilities.

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

 

Subchapter S Corporations

1. Guidance under Sec. 1366.

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

 

Tax Accounting

1. 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, and extended and amended by § 331(c) of ATRA, regarding the election to accelerate carryover AMT credits in lieu of claiming bonus depreciation.

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

3. Final regulations under Sec. 263A regarding the inclusion of negative amounts in additional Sec. 263A costs. Proposed regulations were published on September 5, 2012.

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

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

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

7. Revenue Procedure under Sec. 263(a) regarding the capitalization of certain retail store expenditures.

8. Regulations under Sec. 267 regarding the application of Sec. 1.267(b)-1(b) to partners and partnerships.

9. Revenue Procedure under Sec. 446 updating Rev. Proc. 97-27 and Rev. Proc. 2011-14 providing procedures and rules for automatic and non-automatic changes in method of accounting.

10. Regulations under Sec. 451 regarding advance payments received for goods and services, including amounts received in exchange for the sale or issuance of gift cards, trading stamps, and loyalty points that can be redeemed for goods or services.

11. Regulations under Sec. 453 addressing certain annuity contracts received in exchange for property. 12. Regulations under Sec. 453A regarding contingent payment sales.

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

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

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

16. 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.

17. Regulations under Sec. 472 regarding dollar-value last-in, first-out (LIFO) inventories, including rules for combining pools as a result of a change in method of accounting, certain corporate acquisitions, and certain nonrecognition transactions.

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

19. Guidance regarding the treatment of deferred revenue in taxable asset sales and acquisitions.

 

Tax Administration

1. Regulations under Sec. 3402(q) and Sec. 3406 regarding TIN matching for Forms W-2G.

2. 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.

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

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

5. Guidance under Sec. 6050P regarding the 36-month rule for reporting cancellation of indebtedness when a financial institution is continuing to pursue collection actions.

6. Final regulations under Sec. 6109 regarding PTINs. Proposed regulations were published February 15, 2012.

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

8. 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.

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

10. 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.

11. Guidance under Sec. 6621(d) with regard to interest netting.

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

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

14. Guidance regarding procedures for dealing with de minimis errors on Forms 1099.

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

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

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

18. 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.

19. 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 March 8, 2013.

20. Guidance under Sec. 7123 concerning alternative dispute resolution.

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

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

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

24. Update to Revenue Procedure 2007-56 (Combat Zone and Disaster Relief).

25. Final 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. Proposed regulations were published on December 18, 2012.

26. Regulations under Sec. 7701 to coordinate the entity classification election with the regulated investment company (RIC) election.

27. 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.

28. Guidance under Sec. 301.9100.

29. Regulations revising Circular 230 regarding practice before the IRS. Proposed regulations were published September 17, 2012.

30. Final regulations relating to the masking of taxpayer identification numbers on payee statements. Proposed regulations were published on January 17, 2013.

31. Update to Revenue Procedure 87-24 dealing with administrative appeals and disposition of Tax Court cases.

32. Update to Revenue Ruling 90-5 dealing with Saturday, Sunday and holiday rules for filing.

33. Guidance prescribing the electronic signature requirements for tax returns and other documents submitted to the IRS.

 

Tax-Exempt Bonds

1. Guidance on reallocations of New Clean Renewable Energy Bonds under Sec. 54C.

2. Guidance on the definition of political subdivision under Sec. 103 for purposes of the tax-exempt, tax credit, and direct pay bond provisions.

3. Guidance under Sec. 141 relating to private activity bonds.

4. Guidance under Sec. 142 to provide temporary relief after a declared disaster.

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

6. 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.

 

APPENDIX -- Regularly Scheduled Publications

 

FEBRUARY 2014

--Revenue Ruling setting forth tables of the adjusted applicable federal rates for the current month for purposes of Secs. 42, 382, 1274, 1288, and 7520.

--Notice setting forth the corporate bond weighted average interest rates, the 24-month average segment rates, and the funding transitional segment rates used to determine the minimum required contribution for plan years beginning in February 2014, and the minimum present value transitional rates for January 2014.

--Notice under Sec. 911 on the Housing Cost Amount for 2014.

 

MARCH 2014

--Revenue Ruling setting forth tables of the adjusted applicable federal rates for the current month for purposes of Secs. 42, 382, 1274, 1288, and 7520.

--Guidance providing the 2014 calendar year resident population estimates used in determining the state housing credit ceiling under § 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 2014 for use in valuing personal flights on employer-provided aircraft.

--Notice setting forth the corporate bond weighted average interest rates, the 24-month average segment rates, and the funding transitional segment rates used to determine the minimum required contribution for plan years beginning in March 2014, and the minimum present value transitional rates for February 2014.

 

APRIL 2014

--Revenue Ruling setting forth tables of the adjusted applicable federal rates for the current month for purposes of Secs. 42, 382, 1274, 1288, and 7520.

--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.

--Notice setting forth the corporate bond weighted average interest rates, the 24-month average segment rates, and the funding transitional segment rates used to determine the minimum required contribution for plan years beginning in April 2014, and the minimum present value transitional rates for March 2014.

--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 2014

--Revenue Ruling setting forth tables of the adjusted applicable federal rates for the current month for purposes of Secs. 42, 382, 1274, 1288, and 7520.

--Notice setting forth the corporate bond weighted average interest rates, the 24-month average segment rates, and the funding transitional segment rates used to determine the minimum required contribution for plan years beginning in May 2014, and the minimum present value transitional rates for April 2014.

--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 2015.

 

JUNE 2014

--Revenue Ruling setting forth tables of the adjusted applicable federal rates for the current month for purposes of Secs. 42, 382, 1274, 1288, and 7520.

--Revenue Ruling under Sec. 6621 regarding the applicable interest rates for overpayments and underpayments of tax for the period July through September 2014.

--Notice setting forth the corporate bond weighted average interest rates, the 24-month average segment rates, and the funding transitional segment rates used to determine the minimum required contribution for plan years beginning in June 2014, and the minimum present value transitional rates for May 2014.

 


Copyright 2013 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. Articles in this publication are not intended to be used, and cannot be used, for the purpose of avoiding accuracy-related penalties that may be imposed on a taxpayer. The information is not necessarily a complete summary of all materials on the subject. Copyright is not claimed on material from U.S. Government sources.--ISSN 1089-1536


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--Last Update 02/24/14