Internal Revenue Bulletin: 2014-41
October 6, 2014
Removal of Allocation Rule for Disbursements from Designated Roth Accounts to Multiple Destinations
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 October 2014.
This revenue procedure provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to the methods of accounting provided in §§ 1.168(i)–1, 1.168(i)–7, and 1.168(i)–8 of the Income Tax Regulations. This revenue procedure also allows a late partial disposition election under § 1.168(i)–8 to be treated as a change in method of accounting for a limited period of time. Finally, this revenue procedure also modifies section 10.11 of the APPENDIX of Rev. Proc. 2011–14 regarding a change to the method of accounting described in Rev. Proc. 2014–16, 2014–9 I.R.B. 606, for amounts paid to acquire, produce, or improve tangible property. Rev. Proc. 2014–54 modifies the procedures in Rev. Proc. 2011–14, 2011–4 I.R.B. 330, and Rev. Proc. 2014–17, 2014–12 I.R.B. 661, regarding certain changes in method of accounting for dispositions of tangible depreciable property.
Notice 2014–55 expands the application of the permitted change rules for health coverage under a § 125 cafeteria plan and addresses two specific situations in which a § 125 cafeteria plan participant is permitted to revoke his or her election under a § 125 cafeteria plan during a period of coverage.
These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance providers. Section 162(m)(6) was enacted as part of the Patient Protection and Affordable Care Act (Public Law 111–148, 124 Stat. 119, 868 (2010))
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