Internal Revenue Bulletin: 2016-33
August 15, 2016
These proposed regulations (REG–103058–16) address various issues under section 6055, including identifying the health insurance issuer as the reporting entity for catastrophic health coverage enrolled in through the Health Insurance Marketplace and clarifying the circumstances when reporting is not required of individuals who are covered by more than one plan or program that is minimum essential coverage. In addition, these proposed regulations modify the taxpayer identification number (TIN) solicitation requirements that section 6055 reporting entities must follow to qualify for relief from penalties for a failure to report a TIN.
This document contains proposed regulations that relate to the education tax credit under section 25A, the information reporting requirements under section 6050S and implements amendments under the Trade Preferences Extension Act of 2015 (TPEA) and the Protecting Americans from Tax Hikes Act of 2015 (PATH).
Announcement 2016–27 provides guidance to jurisdictions that are treated as if they have an IGA in effect and FFIs located in those jurisdictions. Each jurisdiction that is treated as if it has an IGA in effect and that wishes to be continue to be treated as if it has an IGA in effect must provide the Treasury Department, by December 31, 2016, with a detailed explanation of why the jurisdiction has not yet brought the IGA into force and provide a step-by-step plan that the jurisdiction intends to follow in order to sign the IGA (if it has not been signed) and bring the IGA into force, including expected dates for achieving each step. Treasury will then evaluate the submission and determine whether the jurisdiction will continue to be treated as if it has an IGA in effect. If a jurisdiction ceases to be treated as if it has an IGA in effect, an FFI in that jurisdiction will no longer be able to rely on the IGA to be treated as complying with and exempt from withholding under, FATCA. Such FFIs generally will have to enter into FFI Agreements in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations.
This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act).
Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to elect to include in gross income, as compensation for services, the fair market value of substantially nonvested property at the time of transfer. This election is made by filing a written statement with the Internal Revenue Service no later than 30 days after the date that the property is transferred. These final regulations eliminate the regulatory requirement that a copy of a § 83(b) election be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred.
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