Internal Revenue Bulletin: 2016-48
November 28, 2016
This document withdraws portions of a notice of proposed rulemaking (INTL–49–86, subsequently converted to REG–209001–86) published in the Federal Register (53 FR 22186) on June 14, 1988, (the 1988 NPRM). The withdrawn portions relate to stock redemptions through related corporations, the application of section 956 to United States property indirectly held by a controlled foreign corporation (CFC), and certain related party factoring transactions, as well as the definition of the term “obligation” for purposes of section 956.
This document contains proposed regulations that provide rules regarding the determination of the amount of United States property treated as held by a controlled foreign corporation (CFC) through a partnership. The proposed regulations affect United States shareholders of CFCs.
This notice updates the appendix to Notice 2013–1, which lists the Indian tribes who have settled tribal trust cases against the United States. Notice 2012–60 originally was published in IRB 2012–41 (October 9, 2012). Notice 2012–60 was superceded by Notice 2013–1 IRB 2013–3, and the appendix to Notice 2013–1 was superceded by Notice 2013–16 (IRB 2013–14), then Notice 2013–36, then Notice 2013–55, then Notice 2014–22, Notice 2014–38, then Notice 2014–61, and then Notice 2015–20. However, sixteen additional tribes have settled cases against the United States since the publication of Notice 2016–41, so we are seeking to publish an updated appendix to Notice 2013–1. This notice would supersede Notice 2016–41.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2016 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2016, and the 30-year Treasury rates. These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA).
This document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income (FPHCI), as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions. The final regulations affect United States shareholders of CFCs.
This document contains final regulations that remove the 36-month non-payment testing rule from the list of identifiable events that cause a deemed discharge that must be reported to the IRS on a Form 1099–C.
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