Internal Revenue Bulletin: 2014-47
November 17, 2014
Table of Contents
This notice of proposed rulemaking (NPRM) provides rules that prescribe how a partner should measure its interest in a partnership’s unrealized receivables and inventory items, and that provide guidance regarding the tax consequences of a distribution that causes a reduction in that interest, thus requiring the recognition of ordinary income. The NPRM takes into account statutory changes that have occurred subsequent to the issuance of the existing regulations. The NPRM affects partners in partnerships that own unrealized receivables and inventory items and that make a distribution to one or more partners.
The “base period T-bill rate” for the period ending September 30, 2014, is published, as required by section 995(f) of the Internal Revenue Code.
The loss payment patterns and discount factors are set forth for the 2014 accident year. These factors will be used for computing discounted unpaid losses under § 846 of the Code.
The salvage discount factors are set forth for the 2014 accident year. These factors will be used for computing discounted estimated salvage recoverable under § 832 of the Code.
This procedure sets forth the 2015 cost-of-living adjustments to certain items due to inflation as required under various provisions of the Code and Service guidance.
This notice designates the Ebola virus outbreak in the West African countries of Guinea, Liberia, and Sierra Leone as a qualified disaster for purposes of section 139 of the Code.
This notice provides guidance on the treatment of leave-based donation programs to aid victims of the Ebola virus outbreak in the West African countries of Guinea, Liberia, and Sierra Leone for income and employment tax purposes.
|More Internal Revenue Bulletins|