Internal Revenue Bulletin:  2014-3 

January 13, 2014 

INCOME TAX


TD 9650T.D. 9650

These temporary and final regulations provide guidance on determining the ownership of a passive foreign investment company, the annual filing requirements for shareholders of PFICs, and an exclusion from certain filing requirements for shareholders that constructively own interests in certain foreign corporations.

REG–140974–11REG–140974–11

This is a notice of proposed rulemaking by cross-reference to temporary regulations. The cross-referenced temporary regulations provide guidance on determining the ownership of a passive foreign investment company, the annual filing requirements for shareholders of PFICs, and an exclusion from certain filing requirements for shareholders that constructively own interests in certain foreign corporations. Comments requested by March 31, 2014.

REG–113350–13REG–113350–13

This document withdraws a portion of proposed regulations issued under section 1291 on April 1, 1992. The withdrawn portion relates to the definitions of the terms pedigreed QEF, section 1291 fund, shareholder, indirect shareholder, and to annual information reporting requirements applicable to certain shareholders of passive foreign investment companies. A portion of REG–209054–87 withdrawn.

Rev. Proc. 2014–12Rev. Proc. 2014–12

This revenue procedure establishes the requirements under which the Internal Revenue Service will not challenge partnership allocations of section 47 credits by a partnership to its partners.

Rev. Proc. 2014–13Rev. Proc. 2014–13

This revenue procedure provides guidance to foreign financial institutions (FFIs) entering into an FFI agreement with the Internal Revenue Service under section 1471(b) of the Internal Revenue Code and § 1.1471–4 of the Treasury Regulations (the FFI agreement) to be treated as participating FFIs. The revenue procedure also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) (reporting Model 2 FFIs) on complying with the terms of an FFI agreement, as modified by the IGA.


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