Internal Revenue Bulletin: 2013-24
June 10, 2013
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for June 2013.
Final regulations under section 336(e) of the Code provide for an election to treat the sale, exchange, or distribution of at least 80 percent of the stock of a domestic subsidiary corporation or a subchapter S corporation as a sale of the corporation’s assets, rather than a sale of its stock.
These proposed regulations provide guidance on the interpretation and application of section 833(c)(5). They guide certain health care organizations in computing and applying the medical loss ratio added to the Code by the Patient Protection and Affordable Care Act. A public hearing is scheduled for September 17, 2013.
The conclusive presumption regulations (sections 1.166-2(d)(1) and (3) of the Income Tax Regulations) reflect a policy that when there is sufficient similarity between the standards a tax administrator uses to permit a deduction for a bad debt and the standards a bank regulator uses to identify a loan that should be charged off, in whole or in part, the tax administrator should accept that determination for purposes of § 166. There have been changes to the standards used by bank regulators to determine bad debt. This notice therefore seeks public comment on whether changes in these bank regulatory standards make compliance with the conclusive presumption regulations problematic and whether application of the conclusive presumption regulations continues to be consistent with the principles of section 166.
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