Internal Revenue Bulletin: 2017-6
February 6, 2017
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 setforth the rates for February 2017.
This revenue procedure provides safe harbor conditions under which a management contract does not result in private business use of property financed with governmental tax-exempt bonds under section 141(b) of the Internal Revenue Code or cause the modified private business use test for property financed with qualified 501(c)(3) bonds under section 145(a)(2)(B) to be met.
This notice provides that the hardship exemption from the individual shared responsibility payment under § 5000A, described by the Department of Health and Human Services, for an individual who is not enrolled in health insurance coverage that qualifies for the health coverage tax credit (HCTC) allowed by § 35 for one more months between July 2016 and December 2016, but who would have been eligible for the HCTC under § 35 if enrolled, may be claimed on a Federal income tax return without obtaining a hardship exemption certification from the Marketplace.
This revenue procedure updates the agreements entered into by withholding foreign partnerships (WPs) and withholding foreign trusts (WTs), as provided in Revenue Procedure 2014–47. These agreements were to expire on December 31, 2016, but were extended in Revenue Procedure 2017–15 in anticipation of the new agreements being issued in January 2017. This revenue procedure will apply to WP and WT agreements effective on or after the date of issuance of this revenue procedure. The WP and WT agreements are updated consistent with recently published guidance, including the qualified intermediary withholding agreement, which was published in Revenue Procedure 2017–15. The revenue procedure also provides information on submitting an application or request for renewal of a WP or WT agreement.
In general, S corporations, regulated investment companies (“RICs”), and real estate investment trusts (“REITs”) are not taxed at the corporate level (in the case of S corporations) or rarely incur corporate-level tax (in the case of RICs and REITs). An exception to this general rule occurs when an S corporation, a RIC, or a REIT disposes of certain property previously held by a C corporation within a specified period of time, known as the “recognition period.” The length of the recognition period for S corporations is provided by statute, while the length of the recognition period for RICs and REITs is provided by regulations. These final regulations will conform the length of the recognition period for RICs and REITs to the length of the recognition period for S corporations.
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