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IRB 2013-11

Table of Contents
(Dated March 11, 2013)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2013-11. 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.

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Highlights of This Issue

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.

INCOME TAX

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2013.

Final regulations under section 304 of the Code addresses sales of stock between related corporations. The regulations finalize proposed regulations and remove temporary regulations that apply to certain sales of stock that are recharacterized as contributions and redemptions, but that are structured with a principal purpose of redesignating the issuing corporation or the acquiring corporation. The regulations affect persons treated as receiving distributions in redemption of stock as a result of such transactions.

General rules and specifications for substitute forms and schedules. This procedure provides guidelines and general requirements for the development, printing, and approval of substitute tax forms. This procedure will be reproduced as the next revision of Publication 1167. Rev. Proc. 2011-61 superseded.

This procedure extends the deadline to comply with the mandatory language requirements in Rev. Proc. 2013-14. Revenue Procedure 2013-14 modified.

EMPLOYEE PLANS

This notice provides guidance on the 25-year average segment rates that are applied to adjust the otherwise applicable 24-month average segment rates that are used to compute the minimum contribution requirements for single-employer defined benefit plans under section 430 of the Code and section 303 of the Employee Retirement Income Security Act of 1974 (ERISA) for plan years beginning in 2013. The guidance reflects the changes made to the Code and ERISA by the Moving Ahead for Progress in the 21st Century Act (MAP-21), Pub. L. 112-141.

This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to include the correct addresses for submitting applications for determination letters and comments submitted by interested parties, in accordance with the corrections to Rev. Proc. 2013-6 made by Ann. 2013-13, 2013-9 I.R.B. 532. Rev. Proc. 2013-6 revised.

EXEMPT ORGANIZATIONS

Final and temporary regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). These final regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The final regulations also provided the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the temporary regulations require an annual payout of the greater of 3.5 percent of the fair market value of non-exempt-use assets or 85 percent of adjusted net income.

Final and temporary regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). These final regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The final regulations also provided the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the temporary regulations require an annual payout of the greater of 3.5 percent of the fair market value of non-exempt-use assets or 85 percent of adjusted net income.

EMPLOYMENT TAX

General rules and specifications for substitute forms and schedules. This procedure provides guidelines and general requirements for the development, printing, and approval of substitute tax forms. This procedure will be reproduced as the next revision of Publication 1167. Rev. Proc. 2011-61 superseded.

EXCISE TAX

Final and temporary regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). These final regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The final regulations also provided the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the temporary regulations require an annual payout of the greater of 3.5 percent of the fair market value of non-exempt-use assets or 85 percent of adjusted net income.

Final and temporary regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). These final regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The final regulations also provided the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the temporary regulations require an annual payout of the greater of 3.5 percent of the fair market value of non-exempt-use assets or 85 percent of adjusted net income.

TAX CONVENTIONS

The following is a copy of the Competent Authority Agreement (“the Agreement”) released to the public on January 31, 2013, by the Competent Authorities of the United States and Norway regarding the eligibility of entities that are treated as fiscally transparent under the laws of either Contracting State to benefit under the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed on December 3, 1971, and as amended by the Protocol signed on September 19, 1980 (the “Treaty”).

ADMINISTRATIVE

Eliminating printing on paper of the Internal Revenue Bulletin. The IRS is no longer printing paper copies of the Internal Revenue Bulletin (IRB), which the IRS distributed directly to certain stakeholders. Also, the IRS will not create the Cumulative Bulletin (CB) after the 2008-2 edition.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.