Internal Revenue Bulletin:  2013-27 

July 1, 2013 

INCOME TAX


Rev. Proc. 2013-28 Rev. Proc. 2013-28

This procedure provides issuers of qualified mortgage bonds (QMBs) and qualified mortgage credit certificates (MCCs) with average area purchase price safe harbors for statistical areas in the United States and with a nationwide average purchase price for residences in the United States for purposes of the QMB rules under section 143 of the Code and the MCC rules under section 25. Rev. Proc. 2012-25 obsoleted in part.

Announcement 2013-35 Announcement 2013-35

This announcement corrects final regulations (TD 9612) that were published in the Federal Register on February 5, 2013 (78 FR 7997), relating to the tax treatment of noncompensatory options and convertible instruments issued by a partnership. The final regulations generally provide that the exercise of a noncompensatory option does not cause the recognition of immediate income or loss by either the issuing partnership or the option holder. The final regulations also modify the regulations under section 704(b) regarding the maintenance of the partners’ capital accounts and the determination of the partners’ distributive shares of partnership items. The final regulations also contain a characterization rule providing that the holder of a noncompensatory option is treated as a partner under certain circumstances.


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