Removal of Allocation Rule for Disbursements from Designated Roth Accounts to Multiple Destinations

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 October 2014.

This revenue procedure provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to the methods of accounting provided in §§ 1.168(i)–1, 1.168(i)–7, and 1.168(i)–8 of the Income Tax Regulations. This revenue procedure also allows a late partial disposition election under § 1.168(i)–8 to be treated as a change in method of accounting for a limited period of time. Finally, this revenue procedure also modifies section 10.11 of the APPENDIX of Rev. Proc. 2011–14 regarding a change to the method of accounting described in Rev. Proc. 2014–16, 2014–9 I.R.B. 606, for amounts paid to acquire, produce, or improve tangible property. Rev. Proc. 2014–54 modifies the procedures in Rev. Proc. 2011–14, 2011–4 I.R.B. 330, and Rev. Proc. 2014–17, 2014–12 I.R.B. 661, regarding certain changes in method of accounting for dispositions of tangible depreciable property.

Notice 2014–55 expands the application of the permitted change rules for health coverage under a § 125 cafeteria plan and addresses two specific situations in which a § 125 cafeteria plan participant is permitted to revoke his or her election under a § 125 cafeteria plan during a period of coverage.

These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance providers. Section 162(m)(6) was enacted as part of the Patient Protection and Affordable Care Act (Public Law 111–148, 124 Stat. 119, 868 (2010))

This notice provides rules for allocating pretax and after-tax amounts among disbursements that are made to multiple destinations from a qualified plan described in § 401(a) of the Internal Revenue Code. These rules also apply to disbursements from a § 403(b) plan or a § 457(b) plan maintained by a governmental employer described in § 457(e)(1)(A) (a “governmental § 457(b) plan”). Section VI of this notice provides transition rules.

Notice 2014–55 expands the application of the permitted change rules for health coverage under a § 125 cafeteria plan and addresses two specific situations in which a § 125 cafeteria plan participant is permitted to revoke his or her election under a § 125 cafeteria plan during a period of coverage.

Final regulations (TD 9505) concerning hybrid defined benefit plans under Code sections 411(a)(13) and 411(b)(5) were published in 2010. These final regulations, which finalize proposed regulations that were also published in 2010, provide additional guidance concerning hybrid defined benefit plans under Code sections 411(a)(13) and 411(b)(5), as well as section 411(b)(1). In particular, these final regulations provide guidance as to the scope of relief under section 411(a)(13)(A), contain a special rule regarding the application of the 133 1/3 percent rule under section 411(b)(1)(B) to hybrid defined benefit plans, provide additional rules regarding the market rate of return limitation under section 411(b)(5)(B)(i), and provide guidance with respect to the plan termination rules of section 411(b)(5)(B)(vi).

These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance providers. Section 162(m)(6) was enacted as part of the Patient Protection and Affordable Care Act (Public Law 111–148, 124 Stat. 119, 868 (2010))

Notice 2014–49 describes a proposed approach to the application of the look-back measurement method, which may be used to determine if an employee is a full-time employee for purposes of § 4980H of the Internal Revenue Code, in situations in which the measurement period applicable to an employee changes. This notice is intended to address the topics for which guidance was anticipated in section VII.G of the preamble to the final § 4980H regulations (79 FR 8544, 8563 (Feb. 12, 2014)).

Notice 2014–56 provides the applicable dollar amount that applies for determining the fee imposed by §§ 4375 and 4376 for policy years and plan years ending on or after October 1, 2014 and Before September 30, 2015.

Notice 2014–56 provides the applicable dollar amount that applies for determining the fee imposed by §§ 4375 and 4376 for policy years and plan years ending on or after October 1, 2014 and Before September 30, 2015.