§ 1.411(a)-11 Restriction and of. (a) Scope - (1) In general.
Section 411(a)(11) restricts the ability of a to distribute any portion of a 's without the 's consent. Section 411(a)(11) also restricts the ability of to distribute any portion of a 's in optional forms of without complying with specified for determining the of the distribution. If the consent or the of this section are not satisfied, the fails to satisfy the of section 411(a). (2) Accrued benefit.
For of this section, an is taking into consideration the particular optional form in which the is to be distributed. The of an is the of the in the distribution form determined under the. For, a that provides a subsidized early retirement annuity may specify that the optional single sum distribution form of available at early retirement age is the of the subsidized early retirement annuity. In this case, the subsidized early retirement annuity must be used to apply the of this section and the of the single sum distribution. However, if a that provides a subsidized early retirement annuity specifies that the single sum distribution available at early retirement age is the of the normal retirement annuity, then the normal retirement annuity is used to apply the of this section and the of the single sum distribution available at early retirement age.
(b) General consent rules. A must satisfy the consent with respect to the distribution of a 's nonforfeitable with a in excess of the -out limit in effect under of this section.
See paragraphs (3) and (4) for situations where no consent is required. (c) Consent, etc. Requirements - (1) General rule. If an is immediately distributable, section 411(a)(11) permits to provide for the distribution of any portion of a 's nonforfeitable accrued only if the applicable consent are satisfied. (i) No consent is valid unless the has received a general of the material features of the optional forms of available under the. In addition, so long as a is immediately distributable, a must be informed of the right, if any, to defer of the distribution. Furthermore, consent is not valid if a significant detriment is imposed under the on any who does not consent to a distribution.
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Whether or not a significant detriment is imposed shall be determined by the Commissioner by examining the particular. (ii) Consent of the to the distribution must not be made before the receives the of his or her rights specified in this paragraph (c)(2) and must not be made more than 90 days before the date the distribution commences. (iii) A must provide a with of the rights specified in this paragraph (c)(2) at a time that satisfies either paragraph (c)(2)(iii)(A) or of this section: (A) This paragraph (c)(2)(iii)(A) is satisfied if the provides a with of the rights specified in this paragraph (c)(2) no less than 30 days and no more than 90 days before the date the distribution commences.
However, if the, after having received this, affirmatively elects a distribution, a will not fail to satisfy the consent of section 411(a)(11) merely because the distribution commences less than 30 days after the was provided to the, provided the administrator clearly indicates to the that the has a right to at least 30 days to consider whether to consent to the distribution. (B) This paragraph (c)(2)(iii)(B) is satisfied if the - (1) Provides the with of the rights specified in this paragraph (c)(2); (2) Provides the with a of the within the time period described in of this section; and (3) If the so requests after receiving the described in paragraph (c)(2)(iii)(B)( 2) of this section, provides the to the without charge and no less than 30 days before the date the distribution commences, subject to the for the 's waiver of that 30-day period.
The described in paragraph (c)(2)(iii)(B)( 2) of this section must advise the of the right, if any, to defer of the distribution, must set forth a of the distribution under the, must refer the to the most recent version of the (and, in the case of a provided in any document containing information in addition to the, must identify that document and must provide a reasonable indication of where the may be found in that document, such as by index reference or by section heading), and must advise the that, upon request, a copy of the will be provided without charge. (iv) For of satisfying the of this paragraph (c)(2), the administrator may substitute the, within the meaning of, Q&A-10, for the date the distribution commences. (v) See, Q&A-24 for a applicable to consents to loans.
(3) Cash-out limit. (i) Written consent of the is required before the commencement of the distribution of any portion of an if the of the nonforfeitable total is greater than the -out limit in effect under of this section on the date the distribution commences. The consent are deemed satisfied if such does not exceed the -out limit, and the may distribute such portion to the as a single sum. For this must be determined in the same manner as under section 417(e); see § 1.417(e)-1(d). (ii) The -out limit in effect for a date is the described in section 411(a)(11)(A) for the that includes that date. The -out limit in effect for dates in beginning on or after August 6, 1997, is $5,000.
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Organization for practice; registration. Nothing contained in this chapter or in the regulations of the Board shall prohibit the practice of. Code of Virginia. Table of Contents » Title 59.1. Trade and Commerce » Chapter 30. Overhead High Voltage Line Safety Act » § 59.1-411. Trackables Activation Code Instructions: 1. Enter your tracking number in the box below. You can retrieve up to five codes at one time. Click the 'Get Codes.
The -out limit in effect for dates in beginning before August 6, 1997, is $3,500. (iii) Effective date. Paragraphs (c)(3)(i) and of this section apply to made on or after October 17, 2000. However, an is permitted to apply the $5,000 -out limit described in of this section to beginning on or after August 6, 1997.
Otherwise, for prior to October 17, 2000, §§ 1.411(a)-11 and 1.411(a)-11T in effect prior to October 17, 2000 (as contained in revised as of April 1, 2000) apply. (4) Immediately distributable. Consent is required for any distribution while it is immediately distributable, i.e., prior to the later of the time a has attained (as in section 411(a)(8)) or age 62. Once a distribution is no longer immediately distributable, a may distribute the in the form of a in the case of a subject to section 417 or in the normal form in other cases. (5) Death of participant. The consent of section 411(a)(11) do not apply after the death of the.
The consent of section 411(a)(11) do not apply to to an alternate, in section 414(p)(8), except as provided in a qualified relations order pursuant to section 414(p). (7) Section 401(a)(9), etc. The consent of section 411(a)(11) do not apply to the extent that a distribution is required to satisfy the of section 401(a)(9) or 415. See section 401(a)(9) and the regulations thereunder and Q&A 23 for guidance on these.
Notwithstanding any provision to the contrary in section 401(a)(14) or, a may not distribute a 's nonforfeitable with a in excess of the -out limit in effect under of this section while the is immediately distributable unless the consents to such distribution. The failure of a to consent is deemed to be an to defer commencement of of the for of section 401(a)(14) and § 1.401(a)-14. (8) Delegation to Commissioner. The Commissioner, in revenue rulings, notices, and published in the Internal Revenue Bulletin, may modify, or provide with respect to, the and consent of this section. (d) Distribution valuation requirements. In determining the of any distribution of any from a, the must take into specified.
For this, the are the same for valuing as set forth in section 417(e); see. This paragraph applies both before and after the 's death regardless of whether the is immediately distributable. This paragraph also applies whether or not the 's consent is required under paragraphs and of this section. (e) Special rules - (1) Plan termination. The of this section apply before, on and after a. If a terminates and the does not offer an annuity (purchased from a commercial provider), then the may distribute a 's without the 's consent. The preceding sentence does not apply if the, or any within the same as the, maintains another, other than an (as in section 4975(e)(7)).
In such a case, the 's may be without the 's consent to the other if the does not consent to an immediate distribution from the terminating. See section 411(d)(6) and the regulations thereunder for to and terminations. (2) ESOP dividends. The of this section do not apply to any distribution of to which section 404(k) applies. (3) Other rules. See Q&As 14, 17 and 24 for that apply to the section 411(a)(11). (f) Medium for notice and consent - (1) Notice.
The of a 's rights described in of this section or the of that described in of this section must be provided on a written paper document. However, see § 1.401(a)-21 for permitting the use of electronic media to provide applicable to recipients with respect to retirement plans. The consent described in paragraphs (c)(2) and (3) of this section must be given on a written paper document. However, see 1 for permitting the use of electronic media to make with respect to retirement plans. Type regulations.gov FR Doc. RIN TD DEPARTMENT OF THE TREASURY, Internal Revenue Service Correcting amendment. Effective Date: These corrections are effective June 30, 2017.
Applicability Date: The corrections to §§ 1.1441-0; 1.1441-1(b)(7)(ii)(B), (e)(3)(iv)(B) and (C), (e)(4)(ii)(B)( 11 ), (e)(4)(ix)(D), (e)(5)(ii) through (e)(5)(ii)(B), (e)(5)(ii)(D) through (e)(5)(v)(B)( 3 ), (e)(5)(v)(B)( 5 ) through (e)(5)(v)(D), and (f) through (f)(4); 1.1441-1T; 1.1441-3(d)(1); 1.1441-4; 1.6045-1(m)(2)(ii) and (n)(12)(ii); and 1.6049-5(c)(1) through (c)(4) are applicable on January 6, 2017. 26 CFR Part 1 Summary. This document contains corrections to final and temporary regulations (TD 9808), which were published in the Federal Register on Friday, January 6, 2017 (82 FR 2046).
These regulations are related to withholding of tax on certain U.S. Source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. Persons, and portfolio interest paid to nonresident alien individuals and foreign corporations. • 82 FR 29728 - Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities; Correction. This document contains a correction to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) relate to information reporting by foreign financial institutions (FFIs) with respect to U.S. Accounts and withholding on certain payments to FFIs and other foreign entities.
• 82 FR 29728 - Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities; Correction. This document contains corrections to final and temporary regulations (TD 9809) that were published in the Federal Register on Friday, January 6, 2017 (82 FR 2124). The final and temporary regulations under chapter 4 of the Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) relate to information reporting by foreign financial institutions (FFIs) with respect to U.S. Accounts and withholding on certain payments to FFIs and other foreign entities. • 82 FR 29730 - Guidelines for the Streamlined Process of Applying for Recognition of Section 501(c)(3) Status. This document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S.
Source dividend payments. This document also provides guidance to withholding agents that are responsible for withholding U.S. Tax with respect to a dividend equivalent, as well as certain other parties to section 871(m) transactions and their agents. • 82 FR 8165 - Treatment of Certain Interests in Corporations as Stock or Indebtedness; Correction. This document contains final regulations under section 7704(d)(1)(E) of the Internal Revenue Code (Code) relating to the qualifying income exception for publicly traded partnerships to not be treated as corporations for Federal income tax purposes. Specifically, these regulations define the activities that generate qualifying income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or natural resources.
These regulations affect publicly traded partnerships and their partners. • 2017-01-23; vol. 82 # 13 - Monday, January 23, 2017. This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulation (REG-133353-16) that was published in the Federal Register on Friday, December 9, 2016.
The proposed regulations authorize the disclosure of specified return information to the Census Bureau (Bureau) for purposes of structuring the censuses and national economic accounts and conducting related statistical activities authorized by title 13. • 2017-01-19; vol. 82 # 12 - Thursday, January 19, 2017. This document contains final regulations regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code (Code). Specifically, the final regulations modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.
• 82 FR 6368 - Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners. In the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under sections 197, 704, 721(c), and 6038B of the Internal Revenue Code (Code) that address transfers of appreciated property by U.S. Persons to partnerships with foreign partners related to the transferor.
The temporary regulations affect U.S. Partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of these proposed regulations. • 82 FR 6370 - Definition of Dependent. This document withdraws proposed regulations relating to the definition of an authorized placement agency for purposes of a dependency exemption for a child placed for adoption that were issued prior to the changes made to the law by the Working Families Tax Relief Act of 2004 (WFTRA). This document contains proposed regulations that reflect changes made by WFTRA and by the Fostering Connections to Success and Increasing Adoptions Act of 2008 (FCSIAA) relating to the dependency exemption.
This document also contains proposed regulations that, to reflect current law, amend the regulations relating to the surviving spouse and head of household filing statuses, the tax tables for individuals, the child and dependent care credit, the earned income credit, the standard deduction, joint tax returns, and taxpayer identification numbers for children placed for adoption. These proposed regulations change the IRS's position regarding the category of taxpayers permitted to claim the childless earned income credit. In determining a taxpayer's eligibility to claim a dependency exemption, these proposed regulations change the IRS's position regarding the adjusted gross income of a taxpayer filing a joint return for purposes of the tiebreaker rules and the source of support of certain payments that originated as governmental payments. These regulations provide guidance to individuals who may claim certain child-related tax benefits. • 82 FR 7582 - Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners.
This document contains temporary regulations that address transfers of appreciated property by United States persons (U.S. Persons) to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied. The document also contains regulations under sections 197, 704, and 6038B that apply to certain transfers described in section 721. The regulations affect U.S.
Partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross-references to coordinate the application of the temporary regulations. • 2017-01-18; vol. 82 # 11 - Wednesday, January 18, 2017. This document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation.
These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register. • 82 FR 5476 - Rules Regarding Inversions and Related Transactions; Partial Withdrawal of Notice of Proposed Rulemaking. In the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are amending portions of temporary regulations that address certain transactions that are structured to avoid the purposes of section 7874 of the Internal Revenue Code (Code). The temporary regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships.
The text of the temporary regulations in the Rules and Regulations section of this issue of the Federal Register also serves as the text of these proposed regulations. • 82 FR 5477 - Definitions of Qualified Matching Contributions and Qualified Nonelective Contributions. This document contains proposed amendments to the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations relating to certain qualified retirement plans that contain cash or deferred arrangements under section 401(k) or that provide for matching contributions or employee contributions under section 401(m). Under these regulations, employer contributions to a plan would be able to qualify as QMACs or QNECs if they satisfy applicable nonforfeitability and distribution requirements at the time they are allocated to participants' accounts, but need not meet these requirements when they are contributed to the plan. These regulations would affect participants in, beneficiaries of, employers maintaining, and administrators of tax-qualified plans that contain cash or deferred arrangements or provide for matching contributions or employee contributions. • 2017-01-06; vol. 82 # 4 - Friday, January 6, 2017.
This document contains proposed regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) describing the verification requirements (including certifications of compliance) and events of default for entities that agree to perform the chapter 4 due diligence, withholding, and reporting requirements on behalf of certain foreign financial institutions (FFIs) or the chapter 4 due diligence and reporting obligations on behalf of certain non-financial foreign entities. These proposed regulations also describe the certification requirements and procedures for IRS's review of certain trustees of trustee-documented trusts and the procedures for IRS's review of periodic certifications provided by registered deemed-compliant FFIs. In addition, these proposed regulations describe the procedures for future modifications to the requirements for certifications of compliance for participating FFIs.
These proposed regulations also describe the requirements for certifications of compliance for participating FFIs that are members of consolidated compliance groups. In addition, in the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and IRS are issuing temporary regulations that provide additional guidance under chapter 4 (temporary chapter 4 regulations). The text of the temporary chapter 4 regulations also serves as the text of the regulations contained in this document that are proposed by cross-reference to the temporary chapter 4 regulations. The preamble to the temporary chapter 4 regulations explains the temporary chapter 4 regulations and these proposed regulations that cross-reference to the temporary chapter 4 regulations. • 82 FR 1645 - Revision of Regulations Under Chapter 3 Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons. In the Rules and Regulations section of this issue of the Federal Register, the Department of the Treasury (Treasury Department) and the IRS are issuing temporary regulations (TD 9808) that revise certain provisions of the final regulations regarding withholding of tax on certain U.S.
Source income paid to foreign persons and requirements for certain claims for refund or credit of income tax made by foreign persons. The text of the temporary regulations also serves as the text of these proposed regulations. • 82 FR 2046 - Regulations Regarding Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons, Information Reporting and Backup Withholding on Payments Made to Certain U.S. Persons, and Portfolio Interest Treatment. Type regulations.gov FR Doc.
RIN TD DEPARTMENT OF THE TREASURY, Internal Revenue Service Removal of temporary regulations; final regulations; and temporary regulations. Effective date. These regulations are effective on January 6, 2017. Applicability dates. For dates of applicability, see §§ 1.871-14(j), 1.1441-1(f), 1.1441-3(i), 1.1441-4(g), 1.1441-5(g), 1.1441-6(i), 1.1441-7(g), 1.1461-1(i), 1.1461-2(d), 1.6041-1(j), 1.6041-4(d), 1.6042-2(f), 1.6042-3(d), 1.6045-1(q), 1.6049-4(h), 1.6049-5(g), 31.3406(g)-1(g), 31.3406(h)-2(i), and 301.6402-3(f). 26 CFR Parts 1, 31, and 301 Summary. This document contains final and temporary regulations regarding withholding of tax on certain U.S.
Source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. Persons, and portfolio interest paid to nonresident alien individuals and foreign corporations. This document finalizes (with minor changes) certain proposed regulations under chapters 3 and 61 and sections 871, 3406, and 6402 of the Internal Revenue Code of 1986 (Code), and withdraws corresponding temporary regulations.
This document also includes temporary regulations providing additional rules under chapter 3 of the Code. The text of the temporary regulations also serves as the text of the proposed regulations set forth in a notice of proposed rulemaking published in the Proposed Rules section of this issue of the Federal Register. The temporary regulations affect persons making payments of U.S. Source income to foreign persons. • 82 FR 2124 - Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities. This document contains final and temporary regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) regarding information reporting by foreign financial institutions (FFIs) with respect to U.S.
Accounts and withholding on certain payments to FFIs and other foreign entities. This document finalizes (with changes) certain proposed regulations under chapter 4, and withdraws corresponding temporary regulations.
This document also includes temporary regulations providing additional rules under chapter 4. The text of the temporary regulations also serves as the text of proposed regulations set forth in a notice of proposed rulemaking published in the Proposed Rules section of this issue of the Federal Register. The regulations included in this document affect persons making certain U.S.-related payments to FFIs and other foreign persons and payments by FFIs to other persons. • 2016-12-30; vol. 81 # 251 - Friday, December 30, 2016.
This document contains final regulations under section 6041 regarding the filing of information returns to report winnings from bingo, keno, and slot machine play. The rules update the existing requirements regarding the filing, form, and content of such information returns; allow for an additional form of payee identification; and provide an optional aggregate reporting method.
The final regulations affect persons who pay winnings of $1,200 or more from bingo and slot machine play, $1,500 or more from keno, and recipients of such payments. • 2016-12-29; vol. 81 # 250 - Thursday, December 29, 2016.
This document contains proposed regulations prescribing mortality tables to be used by most defined benefit pension plans. The tables specify the probability of survival year-by-year for an individual based on age, gender, and other factors. This information is used (together with other actuarial assumptions) to calculate the present value of a stream of expected future benefit payments for purposes of determining the minimum funding requirements for the plan. These mortality tables are also relevant to determining the minimum required amount of a lump-sum distribution from such a plan.
In addition, this document contains proposed regulations to update the requirements that a plan sponsor must meet in order to obtain IRS approval to use mortality tables specific to the plan for minimum funding purposes (instead of the generally applicable mortality tables). These regulations affect participants in, beneficiaries of, employers maintaining, and administrators of certain retirement plans. • 81 FR 95929 - Nuclear Decommissioning Funds. This document provides proposed changes to the regulations under section 468A of the Internal Revenue Code of 1986 (Code) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants and the use of the amounts in those trusts to decommission nuclear plants.
The proposed regulations revise certain provisions to: Address issues that have arisen as more nuclear plants have begun the decommissioning process; and clarify provisions in the current regulations regarding self-dealing and the definition of substantial completion of decommissioning. • 2016-12-28; vol. 81 # 249 - Wednesday, December 28, 2016. This document contains final regulations that provide guidance on determining ownership of a passive foreign investment company (PFIC) and on certain annual reporting requirements for shareholders of PFICs to file Form 8621, “Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund.” In addition, the final regulations provide guidance on an exception to the requirement for certain shareholders of foreign corporations to file Form 5471, “Information Return of U.S. Persons with Respect to Certain Foreign Corporations.” The regulations finalize proposed regulations and withdraw temporary regulations published on December 31, 2013. The final regulations affect United States persons that own interests in PFICs, and certain United States shareholders of foreign corporations. • 81 FR 95470 - United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction.
This document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. • 81 FR 95471 - United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction. This document contains corrections to the final regulations (TD 9792) that were published in the Federal Register on Thursday, November 3, 2016 (81 FR 76497). The final regulations provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. • 81 FR 95541 - United States Property Held by Controlled Foreign Corporations Through Partnerships With Special Allocations; Correction.
This document contains temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code (Code) to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) of the Code causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. These temporary regulations affect corporations that distribute the stock or securities of controlled corporations and the shareholders or security holders of those distributing corporations. The text of these temporary regulations also serves as the text of the proposed regulations in the related notice of proposed rulemaking (REG-140328-15) set forth in the Proposed Rules section in this issue of the Federal Register.
• 81 FR 91755 - Premium Tax Credit Regulation VI. This document contains final regulations relating to the health insurance premium tax credit (premium tax credit). These final regulations affect individuals who enroll in qualified health plans through Health Insurance Exchanges (Exchanges, also called Marketplaces) and claim the premium tax credit, and Exchanges that make qualified health plans available to individuals and employers. These final regulations also affect individuals who are eligible for employer-sponsored health coverage.
• 81 FR 91888 - Guidance Regarding Predecessors and Successors Under Section 355(e); Limitation on Gain Recognition; Guidance Under Section 355(f). In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. Those temporary regulations affect corporations that distribute the stock or securities of controlled corporations and their shareholders or security holders of those distributing corporations.
The text of those temporary regulations serves as the text of these proposed regulations. • 2016-12-16; vol. 81 # 242 - Friday, December 16, 2016.
This document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The regulations also combine certain sections of the existing regulations under section 367(a) into a single section. This document also withdraws certain temporary regulations. • 2016-12-13; vol.
81 # 239 - Tuesday, December 13, 2016. This document contains final regulations that provide guidance under section 987 of the Internal Revenue Code (Code) regarding the determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to section 987, as well as the timing, amount, character, and source of any section 987 gain or loss. Taxpayers affected by these regulations are corporations and individuals that own QBUs subject to section 987. In addition, published elsewhere in this issue of the Federal Register, temporary and proposed regulations (the temporary regulations) are being issued under section 987 to address aspects of the application of section 987 not addressed in these final regulations. • 81 FR 88854 - Recognition and Deferral of Section 987 Gain or Loss. This document contains temporary regulations under section 987 of the Internal Revenue Code (Code) relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit (QBU) in connection with certain QBU terminations and certain other transactions involving partnerships. This document also contains temporary regulations under section 987 providing: an annual deemed termination election for a section 987 QBU; an elective method, available to taxpayers that make the annual deemed termination election, for translating all items of income or loss with respect to a section 987 QBU at the yearly average exchange rate; rules regarding the treatment of section 988 transactions of a section 987 QBU; rules regarding QBUs with the U.S.
Dollar as their functional currency; rules regarding combinations and separations of section 987 QBUs; rules regarding the translation of income used to pay creditable foreign income taxes; and rules regarding the allocation of assets and liabilities of certain partnerships for purposes of section 987. Finally, this document contains temporary regulations under section 988 requiring the deferral of certain section 988 loss that arises with respect to related-party loans.
The text of these temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register. In addition, in the Rules and Regulations section of this issue of the Federal Register, final regulations are being issued under section 987 to provide general guidance under section 987 regarding the determination of the taxable income or loss of a taxpayer with respect to a QBU.
• 81 FR 88882 - Recognition and Deferral of Section 987 Gain or Loss. Published elsewhere in this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations under section 987 of the Code relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit (QBU) in connection with certain QBU terminations and certain other transactions involving partnerships. The temporary regulations also contain rules providing: An annual deemed termination election for a section 987 QBU; an elective method, available to taxpayers that make the annual deemed termination election, for translating all items of income or loss with respect to a section 987 QBU at the yearly average exchange rate; rules regarding the treatment of section 988 transactions of a section 987 QBU; rules regarding QBUs with the U.S. Dollar as their functional currency; rules regarding combinations and separations of section 987 QBUs; rules regarding the translation of income used to pay creditable foreign income taxes; and rules regarding the allocation of assets and liabilities of certain partnerships for purposes of section 987.
Finally, the temporary regulations contain rules under section 988 requiring the deferral of certain section 988 loss that arises with respect to related-party loans. The text of the temporary regulations serves as the text of these proposed regulations. • 2016-12-07; vol.
81 # 235 - Wednesday, December 7, 2016. This document contains temporary Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S. Income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. These regulations are necessary to provide guidance on applying section 901(m). The text of the temporary regulations also serves in part as the text of the proposed regulations under section 901(m) (REG-129128-14) published in the Proposed Rules section of this issue of the Federal Register. • 81 FR 88562 - Covered Asset Acquisitions. This document contains proposed Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to transactions that generally are treated as asset acquisitions for U.S.
Income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. In the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under section 901(m) (the temporary regulations), the text of which serves as the text of a portion of these proposed regulations. These regulations are necessary to provide guidance on applying section 901(m). These regulations affect taxpayers claiming foreign tax credits. • 2016-12-05; vol. 81 # 233 - Monday, December 5, 2016. This document contains temporary regulations that modify existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to tax return preparer due diligence.
These temporary regulations implement recent law changes that expand the tax return preparer due diligence penalty under section 6695(g) so that it applies to the child tax credit (CTC), additional child tax credit (ACTC), and the American Opportunity Tax Credit (AOTC), in addition to the earned income credit (EIC). The temporary regulations affect tax return preparers.
The substance of the temporary regulations is included in the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. • 81 FR 87502 - Tax Return Preparer Due Diligence Penalty Under Section 6695(g).
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that will modify the existing regulations related to the penalty under section 6695(g) of the Internal Revenue Code (Code) relating to tax return preparer due diligence. The temporary regulations implement recent law changes that expand the tax return preparer due diligence penalty under section 6695(g) so that it applies to the child tax credit (CTC), additional child tax credit (ACTC), and the American Opportunity Tax Credit (AOTC), in addition to the earned income credit (EIC). The text of those regulations also serves as the text of these proposed regulations. • 2016-12-02; vol. 81 # 232 - Friday, December 2, 2016. This document contains final regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (2) regarding the value of property included in a decedent's gross estate for federal estate tax purposes before June 30, 2016, need not have done so until June 30, 2016.
These final regulations are applicable to executors and other persons who file federal estate tax returns required by section 6018(a) or (b) after July 31, 2015. • 2016-11-28; vol. 81 # 228 - Monday, November 28, 2016.
This document contains proposed regulations that relate to the establishment of dollar-value last-in, first-out (LIFO) inventory pools by certain taxpayers that use the inventory price index computation (IPIC) pooling method. The proposed regulations provide rules regarding the proper pooling of manufactured or processed goods and wholesale or retail (resale) goods. The proposed regulations would affect taxpayers who use the IPIC pooling method and whose inventory for a trade or business consists of manufactured or processed goods and resale goods. • 2016-11-25; vol.
81 # 227 - Friday, November 25, 2016. This document contains proposed regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These proposed regulations would provide guidance on changes made by the Pension Protection Act of 2006 and would provide other modifications to these rules as well. These regulations would affect participants, beneficiaries, sponsors, and administrators of defined benefit pension plans. This document also provides a notice of a public hearing on these proposed regulations.
• 2016-11-23; vol. 81 # 226 - Wednesday, November 23, 2016. This document contains proposed regulations relating to the application of section 514(c)(9)(E) of the Internal Revenue Code (Code) to partnerships that hold debt-financed real property and have one or more (but not all) qualified tax-exempt organization partners within the meaning of section 514(c)(9)(C). The proposed regulations amend the current regulations under section 514(c)(9)(E) to allow certain allocations resulting from specified common business practices to comply with the rules under section 514(c)(9)(E).
These regulations affect partnerships with qualified tax-exempt organization partners and their partners. • 2016-11-17; vol. 81 # 222 - Thursday, November 17, 2016. This document contains corrections to final and temporary regulations (TD 9788) that were published in the Federal Register on Wednesday, October 5, 2016 (81 FR 69282).
The final and temporary regulations provide rules concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code and when certain obligations are recognized for purposes of determining whether a liability is a recourse partnership liability under section 752. • 81 FR 80993 - Liabilities Recognized as Recourse Partnership Liabilities Under Section 752; Correction.