Internal Revenue Bulletin: 2015-37
September 14, 2015
This document contains proposed regulations that provide guidance regarding the amount of the penalty under section 6707A of the Internal Revenue Code (Code) for failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction.
These proposed regulations would make it easier for individuals to satisfy the presence test for qualifying as a bona fide resident of a U.S. possession or territory under section 937(a). In counting days of presence in the possession under the presence test, the proposed regulations generally would allow an individual to include up to 30 days that the individual was outside the possession and the United States, provided that the individual was present for more days in the possession than in the United States.
The proposed regulations provide guidance to taxpayers on the amendments made to section 199 by the Energy Improvement and Extension Act of 2008 and the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, involving oil related qualified production activities income and qualified films, and the American Taxpayer Relief Act of 2012, involving activities in Puerto Rico. The proposed regulations also provide guidance on (1) determining domestic production gross receipts, (2) the terms manufactured, produced, grown, or extracted, (3) contract manufacturing, (4) hedging transactions, (5) construction activities, (6) allocating cost of goods sold, and (7) agricultural and horticultural cooperatives.
Proposed regulations under section 36B of the Code provide that an eligible employer-sponsored plan does not meet the minimum value requirement unless it provides substantial coverage of inpatient hospitalization services and physician services.
Final and temporary regulations relating to the allocation of W–2 wages for purposes of the W–2 wage limitation on the amount of a taxpayer’s deduction related to domestic production activities. Specifically, the temporary regulations provide guidance on (1) the allocation of W–2 wages paid by two or more taxpayers that are employers of the same employees during a calendar year and (2) the determination of W–2 wages if the taxpayer has a short taxable year.
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