Internal Revenue Bulletin:  2014-13 

March 24, 2014 

INCOME TAX


REG–130967–13REG–130967–13

Sections 1471 through 1474 of the Internal Revenue Code, commonly known as FATCA, generally require a U.S. withholding agent to withhold tax on certain payments to a foreign financial institution (FFI) that has not agreed to provide the IRS with certain information regarding its United States accounts. Under FATCA, a U.S. withholding agent must also withhold tax on certain payments to a nonfinancial foreign entity (NFFE) that has not provided the withholding agent with information about the NFFE's substantial United States owners. Temporary regulations in TD 9657 revise and refine final FATCA regulations, TD 9610, and provide guidance to persons making certain U.S. related payments to FFIs and NFFEs, and payments by FFIs to other persons. The text of the temporary regulations also serves as the text of these proposed regulations.

REG–134361–12REG–134361–12

Payors of payments of certain U.S. source income to foreign persons are subject to comprehensive payee documentation, information reporting, and tax withholding requirements under sections 1441, 1442, and 1443 (contained in chapter 3 of subtitle A of the Internal Revenue Code). These payments may also be subject to comprehensive payee due diligence and documentation, information reporting, and tax withholding rules under chapter 4 (sections 1471–1474), Chapter 61, and section 3406. Temporary regulations in TD 9658 provide guidance coordinating and conforming the due diligence, information reporting, and tax withholding rules under chapter 3 and 61 and section 3406 with the requirements under chapter 4. The text of the temporary regulations also serves as the text of these proposed regulations.

Notice 2014–11Notice 2014–11

This notice provides the maximum vehicles values for use with the special valuation rules under regulation section 1.61–21(d) and (e) for 2014. These values are adjusted annually for inflation by reference to the Consumer Price Index.

Notice 2014–14Notice 2014–14

This notice announces the intention of Treasury and the IRS to modify the rule relating to specified ELIs when finalizing the proposed regulations published in the Federal Register at 78 FR 73128 (2013) on December 5, 2013. Specifically, final regulations will provide that the rules relating to specified equity-linked instruments issued on or after 90 days of the date of publication of final regulations.

Rev. Proc. 2014–24Rev. Proc. 2014–24

Consolidated returns; failure to properly include subsidiary. This revenue procedure provides a determination by the Commissioner under § 1.1502–75(b) that if an affiliated group satisfies the conditions described in the revenue procedure, a subsidiary that actually failed to file a Form 1122 is treated as if it filed such form and thus joined in the making of a consolidated return by the affiliated group.

Notice 2014–17Notice 2014–17

The notice, as interim guidance, provides a general rule that per capita distributions to members of Indian tribes made from funds held in trust by the Secretary of the Interior (“Trust Account”) are excluded from the gross income of the members of the tribe receiving the per capita distributions. It also provides an exception where distributions to tribal members from a Trust Account will not be excluded from gross income under 26 U.S.C. § 61 to the members of the tribe receiving the distributions if the Trust Account is used to mischaracterize taxable income as nontaxable per capita distributions.

T.D. 9657T.D. 9657

Section 1471 through 1474 of the Internal Revenue code, commonly known as FATCA, generally require a U.S. withholding agent to withhold tax on certain payments to a foreign financial institution (FFI) that has not agreed to provide the IRS with certain information regarding its United States accounts. Under FATCA, a U.S. withholding agent must also withhold tax on certain payments to a nonfinancial foreign entity (NFFE) that has not provided the withholding agent with information about the NFFE's substantial United States owners. These regulations revise and refine final FATCA regulations, TD 9610, and provide guidance to person making certain U.S. related payments to FFIs and NFFEs, and payments by FFIs to other persons. TD 9657. Published: March 6, 2014.

T.D. 9658T.D. 9658

Payors of payments of certain U.S. source income to foreign person are subject to comprehensive payee documentation, information reporting, and tax withholding requirements under sections 1441, 1442, and 1443 (contained in chapter 3 of subtitle A of the Internal Revenue Code). These payments may also be subject to comprehensive payee due diligence and documentation, information reporting, and tax withholding rules under chapter 4 (section 1471–1474), chapter 61, and section 3406. These regulations provide guidance coordinating and conforming the due diligence, information reporting, and tax withholding rules under chapters 3 and 61 and section 3406 with the requirements under chapter 4.

T.D. 9660T.D. 9660

Final regulations provide rules under section 6055 of the Code, enacted by section 1502 of the Affordable Care Act, relating to information reporting by persons that provide minimum essential coverage to individuals.


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