Internal Revenue Bulletin: 2013-44
October 28, 2013
Table of Contents
These final regulations remove any reference to, or requirement of reliance on, credit ratings in regulations under the Internal Revenue Code and provide substitute standards of credit-worthiness where appropriate, pursuant to the Dodd-Frank Act.
Research expenditures under Section 174. Theses proposed regulations provide guidance on the treatment of amounts paid or incurred in connection with the development of tangible property, including pilot models. Comments requested by December 5, 2013. A public hearing is scheduled for January 8, 2014.
These proposed regulations apply when a corporation that is subject to U.S. income tax acquires loss property tax-free from a liquidating subsidiary, from shareholders or others in a capital contribution, or from another corporation or person in a reorganization, and the loss in the acquired property accrued outside the U.S. tax system. The proposed regulations provide guidance for preventing the importation of loss in such cases by requiring the bases of the assets received to be equal to value.
Clarification of Notice 2013–29. Notice 2013–29 provided two methods to determine when construction has begun on a qualified energy facility. This notice clarifies Notice 2013–29 regarding (i) the determination of whether a taxpayer satisfies either of those methods with respect to a facility, (ii) the applicability of the “master contract” provision in that notice, and (iii) the effect of a transfer of a facility after construction has begun.
In order to provide emergency housing relief needed as a result of the devastation caused by severe storms, flooding, landslides, and mudslides in Colorado, this notice temporarily suspends certain requirements under § 142(d) for qualified residential rental projects financed with exempt facility bonds issued by state and local governments under § 142. To that end, this Notice suspends the income requirements during a temporary housing period that ends September 30, 2014, for units of a Project within which units are occupied by displaced individuals. It also provides certain modifications to the beginning and ending dates of the qualified project period for a Project occupied by displaced individuals, provides that displaced persons are not to be considered transient, and provides 60 days for correcting non-compliant Projects at the end of the temporary housing period.
The Internal Revenue Service is suspending certain requirements under § 42 of the Code for low-income housing credit projects to provide emergency housing relief needed as a result of the devastation caused by recent weather-related disasters in the State of Colorado.
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