Internal Revenue Bulletin: 2016-6
February 8, 2016
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 February 2016.
Notice 2016–08 announces that the Treasury Department and the IRS intend to amend the regulations under chapter 3 (sections 1441–1464) and chapter 4 (sections 1471–1474) of the Internal Revenue Code to: (1) Provide that a participating FFI or reporting Model 2 FFI will submit its preexisting account certification to the IRS by the same date it is required to submit its first periodic certifications of compliance. (2) Specify the time period and date for submitting a registered deemed compliant FFI's periodic certification of compliance described in § 1.1471–5(f)(1)(ii)(B), and provide that local FFIs and restricted funds must submit their one-time preexisting account certifications with their first periodic certification of compliance. (3) Modify applicable transitional reporting rules for calendar year 2015 to provide that a participating FFI, reporting Model 2 FFI, or registered deemed-compliant FFI is not required to report gross proceeds paid to, or with respect to, an account held by a nonparticipating FFI. Amendments under both chapters 3 and 4 will specify the circumstances under which a withholding agent may rely upon electronically furnished Forms W–8 and W–9 collected by intermediaries and flow-through entities.
This notice relates to alternative methods of compliance with the rules under sections 853 and 905(c) as they apply when a regulated investment company (RIC) receives a refund of a foreign tax that when paid by the RIC, was treated as paid by the RIC’s shareholders under section 853(b)(2) because an election was made under section 853(a). The notice describes regulations that the Treasury Department and IRS intend to issue which will allow a netting procedure that, if applied by the RICs, will greatly reduce the administrative costs and burdens on the U.S. government, RICs, and the RICs’ shareholders. The notice also provides guidelines for RICs wishing to obtain closing agreements relating to tax consequences arising from the receipt of such refunds.
Credit for Indian Coal Production and Inflation Adjustment Factor for Calendar Year 2015: The notice reports for 2015 the inflation adjustment factor used to determine the availability of the section 45 credit for Indian coal production and includes the credit amount for Indian coal production.
This notice provides the maximum vehicle values for use with the special valuation rules under regulation section 1.61–21(d) and (e) for 2016. These values are adjusted for inflation and must be adjusted annually by reference to the Consumer Price Index.
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