Internal Revenue Bulletin: 2016-45
November 7, 2016
These proposed regulations correspond to temporary regulations (published elsewhere in this edition of the Bulletin (TD 9790)) that treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes.
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, 7872, and other sections of the Code, tables set forth the rates for November 2016.
This procedure provides the 2017 cost-of-living adjustments to certain items due to inflation, as required by various provisions of the Code and Service guidance.
This notice provides rules interpreting the reasonable mortality charge requirement contained in section 7702(c)(3)(B)(i) of the Code. Notice 88–128 supplemented. Notice 2006–95 modified and superseded.
These regulations provide rules that establish threshold documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes, and treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes
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