<!-- TTST:[]: TTC:[]: TTSC:[]: TTT:[IRB]: TTS:[]: TTCP:[IRB 2015-39]: TTCI:[Highlights]: TTB:[]: TTA:[]: TTD:[]: -->

IRB 2015-39

Table of Contents
(Dated September 28, 2015)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2015-39. 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.

View the original PDF version of this Internal Revenue Bulletin

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

This document contains final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations provide that if a taxpayer has identified multiple hedges as being part of a qualified hedging transaction, and the taxpayer has terminated at least one but less than all of the hedges (including a portion of one or more of the hedges), the taxpayer must treat the remaining hedges as having been sold for fair market value on the date of disposition of the terminated hedge.

Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning October 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 revenue procedure describes conditions under which the Internal Revenue Service will treat a regulated investment company (RIC) that invests in one or more other RICs as satisfying the asset diversification requirements of section 851(b)(3)(B) of the Internal Revenue Code.

EMPLOYEE PLANS

This revenue procedure sets forth procedures for plan administrators and plan sponsors that are required to file electronically Form 8955-SSA, "Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits," or Form 5500-EZ, "Annual Return of One-Participant (Owners and Their Spouses) Retirement Plan," to request a waiver of the electronic filing requirement due to economic hardship.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for September 2015 used under § 417(e)(3)(D), the 24-month average segment rates applicable for September 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).

These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also contain guidance regarding the excise tax for failure to satisfy the minimum funding requirements for defined benefit pension plans.

EXEMPT ORGANIZATIONS

Serves notice to potential donors of organizations that have recently filed a timely declaratory judgment suit under section 7428 of the Code, challenging revocation of its status as an eligible donee under section 170(c)(2).

This notice confirms that under section 4944 private foundation managers may consider the relationship between a particular investment and the foundation's charitable purpose when exercising ordinary business care and prudence in deciding whether to make the investment.

ESTATE TAX

These regulations provide guidance on the tax imposed on United States citizens and residents and certain trusts, when a gift or bequest is received, directly or indirectly, from certain individuals who relinquished United States citizenship or ceased to be lawful permanent residents of the United States on or after June 17, 2008.

GIFT TAX

These regulations provide guidance on the tax imposed on United States citizens and residents and certain trusts, when a gift or bequest is received, directly or indirectly, from certain individuals who relinquished United States citizenship or ceased to be lawful permanent residents of the United States on or after June 17, 2008.

EXCISE TAX

This revenue procedure updates Rev. Proc. 2003–78, 2003–2 C.B. 1029, to correct the mailing address and contact numbers for a foreign insurer or reinsurer that requests a closing agreement for an exemption from the excise tax imposed by section 4371, formalize certain requirements for obtaining a closing agreement, and make corresponding changes to the form closing agreements attached as Appendices A and B to Rev. Proc. 2003–78.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.