Internal Revenue Bulletin: 2014-9
February 24, 2014
Table of Contents
This revenue ruling provides guidance on the amount of the life insurance reserves taken into account under § 807 of the Internal Revenue Code for a variable contract where some or all of the reserves are accounted for as part of a life insurance company's separate account reserves. Rev. Rul. 2007–54 is modified and superseded and Rev. Rul. 2007–61 is obsoleted.
TD 9655 includes final Treasury regulations providing guidance under section 4980H of the Internal Revenue Code, as added by the Patient Protection and Affordable Care Act. Section 4980H generally provides that an applicable large employer may be subject to an assessable payment if the employer does not offer minimum essential health coverage to its full-time employees (and their dependents), or if the employer offers its full-time employees (and their dependents) minimum essential health coverage that is not affordable. The regulations affect applicable large employers, defined under section 4980H as employers that employed on average at least 50 full-time employees (including full-time equivalents) on business days during the preceding calendar year.
Notice 2014–10 provides relief from the individual shared responsibility payment required under section 5000A of the Internal Revenue Code for months in 2014 in which individuals have, under Medicaid and chapter 55 of Title 10, U.S.C., limited-benefit health coverage that is not minimum essential coverage.
Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas for purposes of determining the 2014 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k) are reproduced.
Rev. Proc. 2014–16 provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to certain methods of accounting for amounts paid to acquire, produce, or improve tangible property, as well as to change to a reasonable method described in § 1.126A–1(f)(4) for self-constructed assets. The revenue procedure also provides the procedures for changing to a permissible method of accounting under section 263A(b)(2) and § 1.263–3(a)(1) for certain costs related to real property acquired through foreclosure or another similar transaction. Finally, the revenue procedure modifies section 3.09 of the APPENDIX to Rev. Proc. 2011–14 regarding a change to the method of accounting described in Rev. Proc. 2011–43 for taxpayers in the business of transporting, delivering, or selling electricity.
This revenue procedure provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code. This revenue procedure will assist taxpayers with so-called “mezzanine” financing in workouts and similar circumstances.
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