This Announcement is issued pursuant to § 521(b) of Pub. L. 106–170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement (APMA) Program, formerly known as the Advance Pricing Agreement (APA) Program. The first report covered calendar years 1991 through 1999. Subsequent reports covered separately each calendar year 2000 through 2013. This sixteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2014. It does not provide guidance regarding the application of the arm’s length standard.

This Announcement is issued pursuant to § 521(b) of Pub. L. 106–170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement (APMA) Program, formerly known as the Advance Pricing Agreement (APA) Program. The first report covered calendar years 1991 through 1999. Subsequent reports covered separately each calendar year 2000 through 2013. This sixteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2014. It does not provide guidance regarding the application of the arm’s length standard.

The revenue procedure provides instructions, in cases in which the common parent of a consolidated group ceases to exist, for all communications relating to the identification of the agent to act on behalf of the consolidated group pursuant to § 1.1502–77(c) of the Income Tax Regulations. The revenue procedure is the exclusive procedure under § 1.1502–77(c) for making the communications identified in section 3 of this revenue procedure.

Revenue Procedure 2015–29 amplifies section 3.01 of Revenue Procedure 2015–3 and provides that the Service will no longer issue rulings to taxpayers concerning whether the taxpayer meets the requirements of section 45 or Notice 2010–54, 2010–40 I.R.B. 403 for refined coal.

Final regulations under section 1502 of the Code address certain issues raised by the existing regulations concerning the agent for a consolidated group filing a Federal income tax return, as well as questions with respect to the authority of the agent for the group. These final regulations clarify that the agent for the consolidated group that becomes either a partnership or an entity that is disregarded from its owner for Federal income tax purposes remains as the agent for the group. Another change is that in situations where the agent for the group may no longer continue to be the agent for the group, the final regulations provide, under most circumstances, that the continuing agent for the group will be automatically determined by a default selection.

Section 162(m) generally limits the otherwise allowable deduction for compensation paid with respect to a covered employee of a publicly held corporation to no more than $1,000,000 per year. These final regulations clarify that qualified performance-based compensation attributable to stock options and stock appreciation rights must specify the maximum number of shares with respect to which options or rights may be granted to each individual employee. These final regulations also clarify the application of the transition rule for taxpayers that are not publicly held corporations and then become publicly held corporations.

This announcement explains the effect of H.R. 2591, which became Public Law 113–243. The announcement also explains how taxpayers should report the rollover of "airline payment amounts" into traditional IRAs.

Section 162(m) generally limits the otherwise allowable deduction for compensation paid with respect to a covered employee of a publicly held corporation to no more than $1,000,000 per year. These final regulations clarify that qualified performance-based compensation attributable to stock options and stock appreciation rights must specify the maximum number of shares with respect to which options or rights may be granted to each individual employee. These final regulations also clarify the application of the transition rule for taxpayers that are not publicly held corporations and then become publicly held corporations.

This notice provides guidance on how the special rule for expatriate health plans for the 2014 and 2015 fee years under the Expatriate Health Coverage Clarification Act of 2014 applies to the health insurance provider fee under ACA § 9010. Under the notice, a covered entity will receive a reduction in its 2015 fee liability for expatriate health plans, as defined by HHS’s Medical Loss Ratio final rule, that are attributable to the 2014 and 2015 fee years.

This NPRM relates to the exception to the general three-year period of limitations on assessment under section 6501(c)(10) of the Internal Revenue Code (Code) for listed transactions that a taxpayer failed to disclose as required under section 6011.