Proposed regulations under section 704 of the Code remove section 1.704-1(b)(iii)(e) (the de minimis partner rule) because the rule may have resulted in unintended tax consequences.

The notice provides a proposed revenue procedure in which the Service will allow a taxpayer to use a simplified proportional method of accounting for original issue discount (“OID”) on pools of credit card receivables under section 1272(a)(6) of the Code. The proportional method allocates to an accrual period an amount of unaccrued OID that is proportional to the amount of pool principal that is paid by cardholders during the period.

The IRS has revoked its determination that The Big Charity Sale, Inc., of Houston, TX; Echelon Community Services, Inc., of Washington, DC; The GT Foundation of Irvine, CA; Mandala Transformation Foundation of Rafael, CA; San Francisco Medical Research Foundation of Mill Valley, CA; Southern Utah Foundation of Cedar City, UT; and Sunset Non-Profit Housing Association of Murrieta, CA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

Final regulations under section 2036 of the Code provide guidance on the portion of trust property includible in the grantor's gross estate if the grantor has retained the use of the property, the right to an annuity, unitrust, graduated retained interest, or other payment from such property for life, for any period not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death.

Final, temporary, and proposed regulations under section 3121 of the Code would extend the exceptions from taxes under the Federal Insurance Contributions Act and the Federal Unemployment Tax Act under sections 3121(b)(3), 3127, and 3306(c)(5) to entities that are disregarded as separate from their owners for federal tax purposes. The temporary regulations also clarify the existing rule that the owners of disregarded entities, except for qualified subchapter S subsidiaries, are responsible for backup withholding and related information reporting requirements under section 3406.

Final, temporary, and proposed regulations under section 3121 of the Code would extend the exceptions from taxes under the Federal Insurance Contributions Act and the Federal Unemployment Tax Act under sections 3121(b)(3), 3127, and 3306(c)(5) to entities that are disregarded as separate from their owners for federal tax purposes. The temporary regulations also clarify the existing rule that the owners of disregarded entities, except for qualified subchapter S subsidiaries, are responsible for backup withholding and related information reporting requirements under section 3406.

Theft losses from fraudulent investment arrangement. This procedure extends the safe harbor of Rev. Proc. 2009-20 to certain cases in which a lead figure in a specified fraudulent arrangement dies and a state or federal government entity brings a civil complaint against the lead figure or an associated entity. Rev. Proc. 2009-20 modified.