<!-- TTST:[]: TTC:[]: TTSC:[]: TTT:[IRB]: TTS:[]: TTCP:[IRB 2013-24]: TTCI:[Highlights]: TTB:[]: TTA:[]: TTD:[]: -->

IRB 2013-24

Table of Contents
(Dated June 10, 2013)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2013-24. 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.

View the original PDF version of this Internal Revenue Bulletin

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 June 2013.

Final regulations under section 336(e) of the Code provide for an election to treat the sale, exchange, or distribution of at least 80 percent of the stock of a domestic subsidiary corporation or a subchapter S corporation as a sale of the corporation’s assets, rather than a sale of its stock.

These proposed regulations provide guidance on the interpretation and application of section 833(c)(5). They guide certain health care organizations in computing and applying the medical loss ratio added to the Code by the Patient Protection and Affordable Care Act. A public hearing is scheduled for September 17, 2013.

The conclusive presumption regulations (sections 1.166-2(d)(1) and (3) of the Income Tax Regulations) reflect a policy that when there is sufficient similarity between the standards a tax administrator uses to permit a deduction for a bad debt and the standards a bank regulator uses to identify a loan that should be charged off, in whole or in part, the tax administrator should accept that determination for purposes of § 166. There have been changes to the standards used by bank regulators to determine bad debt. This notice therefore seeks public comment on whether changes in these bank regulatory standards make compliance with the conclusive presumption regulations problematic and whether application of the conclusive presumption regulations continues to be consistent with the principles of section 166.

EXEMPT ORGANIZATIONS

The IRS has revoked its determination that Life Extension Foundation, Inc. of Ft. Lauderdale, FL, Mustard Seed Housing, Inc. of Petaluma, CA, and Northwest Regional Emergency Medical Services and Trauma Care Council of Bremerton, WA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

ADMINISTRATIVE

This notice updates the appendix to Notice 2013-1, which lists the Indian tribes that have settled tribal trust cases against the United States. Notice 2012-60 originally was published in I.R.B. 2012-41 (October 9, 2012). Notice 2012-60 was superceded by Notice 2013-1 I.R.B. 2013-3, and the appendix to Notice 2013-1 was superceded by Notice 2013-16 (I.R.B. 2013-14). However, three additional tribes have settled cases against the United States since the publication of Notice 2013-16, so this notice modifies and supersedes the appendix to Notice 2013-16.

This proposed revenue procedure provides issuers of qualified mortgage bonds, as defined in § 143(a) of the Code, and issuers of mortgage credit certificates, as defined in § 25(c), with the United States median gross income figure most recently computed by the Department of Housing and Urban Development (HUD). The proposed revenue procedure also provides these issuers with guidance concerning the area median gross incomes as computed by HUD. Issuers of qualified mortgage bonds (QMB) and mortgage credit certificates (MCC) must use these income figures in determining whether the income limitation placed on the beneficiaries of the mortgages and certificates may be increased because the residences to be financed are located in high housing cost areas. See §§ 25(c)(2)(A)(iii)(IV) and 143(f)(5). Rev. Proc. 2012-16 is obsoleted with exceptions.



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.