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IRB 2013-52

Table of Contents
(Dated December 23, 2013)
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This is the table of contents of Internal Revenue Bulletin IRB 2013-52. 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

Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning January 1, 2014, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for the underpayments, and 5 percent for large corporation underpayments. The rate of interest paid on the portion of a corporation overpayment exceeding $10,000 will be 0.5 percent.

These final regulations provide a definition of the term "specified notional principal contract" with respect to a payment of a dividend equivalent made prior to January 1, 2016. These final regulations also amend other provisions of the Code to address the treatment of dividend equivalents, such as withholding rules.

These proposed regulations describe payments that are dividend equivalents for purposes of section 871(m) and explain how to calculate the amount of a dividend equivalent. These proposed regulations also provide guidance regarding when payments will constitute dividend equivalents and U.S. source income. Comments are requested by March 5, 2014. A public hearing is scheduled for April 11, 2014.

These proposed regulations concern the deductibility of start-up expenditures and organizational expenses for partnerships. The proposed regulations provide guidance regarding the deductibility of start-up expenditures and organizational expenses for partnerships following a technical termination of a partnership. Comments are requested by March 10, 2014.

EMPLOYEE PLANS

This notice provides guidance under § 402A(c)(4)(E) of the Code relating to the expansion of rollovers from § 401(k) plans, § 403(b) plans and governmental § 457(b) plans to designated Roth accounts in the same plan (“in-plan Roth rollovers”). This notice also provides guidance that applies to all in-plan Roth rollovers under § 402A(c)(4). Section 402A(c)(4)(E) was added by § 902 of the American Taxpayer Relief Act of 2012 (“ATRA”), P.L. 112–240. Notice 2010–84 and Rev. Rul. 2004–12 are modified.

This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44, 2007–2 C.B. 54. The 2013 Cumulative List is to be used by plan sponsors and practitioners submitting determination, opinion, or advisory letter applications for plans during the period beginning February 1, 2014 and ending January 31, 2015.

This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in December 2013; the 24-month average segment rates; the funding segment rates applicable for December 2013; and the minimum present value rates for November 2013. The rates in this notice reflect certain changes implemented by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21).

EXEMPT ORGANIZATIONS

These proposed regulations provide guidance to tax-exempt social welfare organizations on political activities related to candidates that will not be considered to promote social welfare. These regulations will affect tax-exempt social welfare organizations and organizations seeking such status. Comments are requested by February 27, 2014.

EMPLOYMENT TAX

This revenue procedure describes and updates the procedure for requesting the IRS authorize a person to act as agent under section 3504 of the Code for purposes of income tax withholding, the Federal Insurance Contributions Act (FICA), and Railroad Retirement Tax Act (RRTA). Special instructions are also set forth for agents authorized to perform acts for purposes of the Federal Unemployment Tax Act (FUTA). Notice 95–18, Rev. Proc. 70–6, Rev. Proc. 80–4, and Notice 2003–70 are affected.

ADMINISTRATIVE

These final regulations amend the regulations that provide user fees for installment agreements and offers in compromise. The amendments affect taxpayers who wish to pay their liabilities through installment agreements and offers in compromise.

Optional standard mileage rates. This notice announces 56 cents as the optional standard mileage rate for substantiating the amount of the deduction for the business use of an automobile, 14 cents as the optional rate for use of an automobile as a charitable contribution, and 23.5 cents as the optional rate for use of an automobile as a medical or moving expense for 2014. The notice also provides the amount a taxpayer must use in calculating reductions to basis for depreciation taken under the business standard mileage rate and the maximum standard automobile cost for automobiles under a FAVR allowance. Notice 2012–72 superseded.



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