Internal Revenue Bulletin: 2014-6
February 3, 2014
Table of Contents
Final regulation that provide guidance on the tax treatment of a debt instrument with a bond premium carryforward in the holder’s final accrual period, including a Treasury bill acquired at a premium.
This regulation identifies certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of whether it is a surrogate foreign corporation under section 7874 and provides guidance under section 7874 with respect to 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 trade or business of a domestic partnership. Notice 2009–78 (2009–40 IRB 452) superseded.
Notice of proposed rulemaking by cross-reference to temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of whether it is a surrogate foreign corporation under section 7874 and provide guidance under section 7874 with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of domestic corporation or of a trade of business of a domestic partnership. Comments and requests for a public hearing must be received by April 17, 2014.
This notice of proposed rulemaking (NPRM) provides rules for determining a taxable beneficiary’s basis in a term interest in a charitable remainder trust upon a sale or other disposition of all interests in the trust to the extent that basis consists of a share of adjusted uniform basis. The NPRM provides that a taxable beneficiary’s assignable share of uniform basis upon the sale of exchange of the taxable beneficiary’s term interest does not include the charitable remainder trust’s undistributed net capital gains or net ordinary income. Comments requested by April 17, 2014.
The proposed regulations provide guidance on certain provisions of the American Jobs Creation Act of 2004 and conform the regulations to statutory changes in the Taxpayer Relief Act of 1997. The proposed regulations provide guidance on the contribution of built-in loss property to a partnership as well as mandatory basis adjustment provisions where a substantial built-in loss or substantial basis reduction exists. The proposed regulations also modify the basis allocation rules to prevent certain unintended consequences of the current basis allocation rules for substituted basis transactions. Finally, the proposed regulations provide additional guidance on allocations resulting from revaluations of partnership property. Submit electronic or written comments by April 16, 2014.
Partners in Charity, Inc. of West Dundee, IL
Christian Credit Outreach, Inc. of Franklin OH
The Hope and Dreams Foundation, of Palo Alto, CA
First Step, Inc. Manahawkin, NJ
Congressional District Programs, Falls Church, VA
Capital Gymnastics, Inc. of Springfield, VA
This announcement contains the Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section as decribed in sections 501(c)(3) and 170(c)(2) of the Code.
Life Extension Foundation Inc. of FT. Lauderdale, FL.
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