This is the table of contents of Internal Revenue Bulletin IRB 2019-23. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.
These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2019 used under § 417(e)(3)(D), the 24-month average segment rates applicable for May 2019, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
Federal rates; adjusted federal rates; adjusted federal long-term rate, the long-term exempt rate, and the blended annual rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for June 2019.
(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)
The notice announces the inflation adjustment factor and phase-out amount for the enhanced oil recovery credit for taxable years beginning in the 2019 calendar year. The notice concludes that because the reference price for the 2019 calendar year ($61.41) exceeds $28 multiplied by the inflation adjustment factor for the 2018 calendar year ($28 multiplied by 1.7334 = $12.88), the enhanced oil recovery credit for qualified costs paid or incurred in 2019 is phased out completely by using a particular ratio.
The Notice publishes Treasury’s estimate of the annual average wellhead price per 1000 cubic feet for all domestic natural gas. This estimate is the “reference price” for purposes of the credit in § 45I. The Treasury Department estimate, for calendar year 2018, is $2.68 per 1000 cubic feet, meaning the § 45I credit is $0.00 per 1,000 cubic feet of qualified natural gas produced from marginal wells
The notice announces that under § 613A(c)(6)(C) of the Internal Revenue Code, the applicable percentage for purposes of determining percentage depletion on marginal properties for calendar year 2019 is 15 percent. The format of the notice is identical to the format of notices previously published on this issue.
These proposed regulations provide rules regarding attribution for purposes of determining whether a person is a related person with respect to a controlled foreign corporation. They also provide rules for determining whether rents are derived in the active conduct of a trade or business for purposes of computing foreign personal holding company income. The regulations would affect United States persons with direct or indirect ownership interests in certain foreign corporations.
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