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IRB 2013-36

Table of Contents
(Dated September 3, 2013)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2013-36. 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

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).

2013 Marginal Production Rates. This notice announces that under § 613A(c)(6)(C) of the Code, the applicable percentage for purposes of determining percentage depletion on marginal properties for calendar year 2013 is 15 percent.

This revenue procedure provides the exclusive simplified methods for taxpayers to request relief for late S corporation elections, ESBT elections, QSST elections, QSub elections, and late corporate classification elections which the taxpayer intended to take effect on the same date that the taxpayer intended that an S corporation election for the entity should take effect. This revenue procedure facilitates the grant of relief to taxpayers that request relief previously provided in numerous other revenue procedures by consolidating the provisions of those revenue procedures into one revenue procedure and extending relief in certain circumstances. Rev. Procs. 97-48, 2003-43, 2004-48, 2004-49, and 2007-62 are affected.

ESTATE TAX

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).

GIFT TAX

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).

EMPLOYMENT TAX

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).

EXCISE TAX

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).

TAX CONVENTIONS

This announcement provides a copy of the Competent Authority Agreement entered into by the competent authorities of the United States and Belgium regarding application of the principles set forth in the Organization for Economic Cooperation and Development Report on the Attribution of Profits to Permanent Establishments in the interpretation of Article 7 (Business Profits) of the Convention Between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, and accompanying Protocol, signed at Brussels on November 27, 2006.

ADMINISTRATIVE

Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)) to permit the disclosure of return information in order to determine a taxpayer’s eligibility in certain health insurance affordability programs. In addition to items specifically enumerated in the statute, section 6103(l)(21)(A)(v) permits the disclosure of items prescribed by the Secretary by regulation as might indicate whether the taxpayer is eligible for a tax credit under section 36B of the Code, or a cost-sharing reduction under section 1402 of the Affordable Care Act. This document contains final regulations detailing items of return information that may be disclosed under section 6103(l)(21).



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