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IRB 2015-26

Table of Contents
(Dated June 29, 2015)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2015-26. 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

These amendments would revise the rules concerning the use of a consolidated group’s losses attributable to a subsidiary in a consolidated return year in which stock of that subsidiary is disposed of.

Proposed regulations that would allow consolidated group members that are partners in the same partnership to aggregate their bases in stock distributed by the partnership for the purpose of limiting the application of rules that might otherwise cause basis reduction or gain recognition. The proposed regulations would also require certain corporations that engage in gain elimination transactions to reduce the basis of corporate assets or to recognize gain.

Proposed regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. These regulations apply when a corporate partner acquires or increases its interest in its own stock held by a partnership in exchange for appreciated property, and also addresses partnership distributions of corporate partner stock to the corporate partner.

Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning July 1, 2015, 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.

This procedure provides specifications for the private printing of red-ink substitutes for the 2015 revisions of certain information returns. This procedure will be reproduced as the next revision of Publication 1179. Rev. Proc. 2014–44 is superseded.

2015 Section 45Q Inflation Adjustment Factor. This notice publishes the inflation adjustment factor for the carbon dioxide (CO2) sequestration credit under § 45Q for calendar year 2015. The notice also includes a statement of the amount of qualified CO2 that has been taken into account for purposes of the § 45Q credit by taxpayers filing an annual report pursuant to section 6 of Notice 2009–83, 2009–2 C.B. 588.

2014 Section 45K(d)(2)(C) Reference Price. This notice publishes the reference price under § 45K(d)(2)(C) of the Internal Revenue Code for calendar year 2014. The reference price applies in determining the amount of the enhanced oil recovery credit under § 43, the marginal well production credit under § 45I, and the percentage depletion in case of oil and natural gas produced from marginal properties under § 613A.

Final and temporary regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. These regulations apply when a corporate partner acquires or increases its interest in its own stock held by a partnership in exchange for appreciated property, and also addresses partnership distributions of corporate partner stock to the corporate partner.

EMPLOYEE PLANS

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for June 2015 used under § 417(e)(3)(D), the 24-month average segment rates applicable for June 2015, and the 30-year Treasury rates. These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA).

This document contains final regulations regarding disclosure of the summary of benefits and coverage and the uniform glossary for group health plans and health insurance coverage in the group and individual markets under the Patient Protection and Affordable Care Act. These final rules amend the 2012 final regulations to incorporate guidance, concerning document requirements and safe harbors, that was issued by the Departments of Labor, HHS and IRS/Treasury subsequent to the publication of the 2012 final regulations.

ESTATE TAX

Revenue Procedure 2015–37 amplifies section 5.01 of Revenue Procedure 2015–3 and provides that, until the Service resolves the issue through publication of a revenue ruling, revenue procedure, regulations, or otherwise, the Service will not issue rulings to taxpayers concerning whether the assets in a grantor trust receive a § 1014 basis step-up at the death of the deemed owner of the trust for income tax purposes when those assets are not includible in the gross estate of that owner under chapter 11 of subtitle B of the Internal Revenue Code.

These final regulations provide rules for determining the applicable credit amount and applicable exclusion amount allowed to the estate of a decedent against the gift or estate tax. In addition, these final regulations provide rules for electing portability of a deceased spousal unused exclusion amount to the surviving spouse and rules regarding the surviving spouse's use of this amount. Portability of a deceased spousal unused exclusion amount is available where the death of the first spouse to die occurs on or after January 1, 2011.

GIFT TAX

These final regulations provide rules for determining the applicable credit amount and applicable exclusion amount allowed to the estate of a decedent against the gift or estate tax. In addition, these final regulations provide rules for electing portability of a deceased spousal unused exclusion amount to the surviving spouse and rules regarding the surviving spouse's use of this amount. Portability of a deceased spousal unused exclusion amount is available where the death of the first spouse to die occurs on or after January 1, 2011.

EXCISE TAX

This document contains final regulations regarding disclosure of the summary of benefits and coverage and the uniform glossary for group health plans and health insurance coverage in the group and individual markets under the Patient Protection and Affordable Care Act. These final rules amend the 2012 final regulations to incorporate guidance, concerning document requirements and safe harbors, that was issued by the Departments of Labor, HHS and IRS/Treasury subsequent to the publication of the 2012 final regulations.

ADMINISTRATIVE

These amendments would revise the rules concerning the use of a consolidated group’s losses attributable to a subsidiary in a consolidated return year in which stock of that subsidiary is disposed of.

This procedure provides specifications for the private printing of red-ink substitutes for the 2014 revisions of certain information returns. This procedure will be reproduced as the next revision of Publication 1179. Rev. Proc. 2014–44 is superseded.

Revenue Procedure 2015–37 amplifies section 5.01 of Revenue Procedure 2015–3 and provides that, until the Service resolves the issue through publication of a revenue ruling, revenue procedure, regulations, or otherwise, the Service will not issue rulings to taxpayers concerning whether the assets in a grantor trust receive a § 1014 basis step-up at the death of the deemed owner of the trust for income tax purposes when those assets are not includible in the gross estate of that owner under chapter 11 of subtitle B of the Internal Revenue Code.



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