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IRB 2016-06

Table of Contents
(Dated February 8, 2016)
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This is the table of contents of Internal Revenue Bulletin IRB 2016-06. 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

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 February 2016.

Notice 2016–08 announces that the Treasury Department and the IRS intend to amend the regulations under chapter 3 (sections 1441–1464) and chapter 4 (sections 1471–1474) of the Internal Revenue Code to: (1) Provide that a participating FFI or reporting Model 2 FFI will submit its preexisting account certification to the IRS by the same date it is required to submit its first periodic certifications of compliance. (2) Specify the time period and date for submitting a registered deemed compliant FFI's periodic certification of compliance described in § 1.1471–5(f)(1)(ii)(B), and provide that local FFIs and restricted funds must submit their one-time preexisting account certifications with their first periodic certification of compliance. (3) Modify applicable transitional reporting rules for calendar year 2015 to provide that a participating FFI, reporting Model 2 FFI, or registered deemed-compliant FFI is not required to report gross proceeds paid to, or with respect to, an account held by a nonparticipating FFI. Amendments under both chapters 3 and 4 will specify the circumstances under which a withholding agent may rely upon electronically furnished Forms W–8 and W–9 collected by intermediaries and flow-through entities.

This notice relates to alternative methods of compliance with the rules under sections 853 and 905(c) as they apply when a regulated investment company (RIC) receives a refund of a foreign tax that when paid by the RIC, was treated as paid by the RIC’s shareholders under section 853(b)(2) because an election was made under section 853(a). The notice describes regulations that the Treasury Department and IRS intend to issue which will allow a netting procedure that, if applied by the RICs, will greatly reduce the administrative costs and burdens on the U.S. government, RICs, and the RICs’ shareholders. The notice also provides guidelines for RICs wishing to obtain closing agreements relating to tax consequences arising from the receipt of such refunds.

Credit for Indian Coal Production and Inflation Adjustment Factor for Calendar Year 2015: The notice reports for 2015 the inflation adjustment factor used to determine the availability of the section 45 credit for Indian coal production and includes the credit amount for Indian coal production.

This notice provides the maximum vehicle values for use with the special valuation rules under regulation section 1.61–21(d) and (e) for 2016. These values are adjusted for inflation and must be adjusted annually by reference to the Consumer Price Index.

EXEMPT ORGANIZATIONS

Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

Notice 2016–09 extends the date by which social welfare organizations must notify the Internal Revenue Service of intent to operate under section 501(c)(4), as required by new section 506, added to the Internal Revenue Code by the Protecting Americans from Tax Hikes Act of 2015. With respect to the separate process by which an organization may, at its option, request a determination that it qualifies for section 501(c)(4) tax-exempt status, the Notice states that organizations seeking IRS recognition of section 501(c)(4) status should continue using Form 1024, “Application for Recognition of Exemption Under Section 501(a),” until further guidance is issued and clarifies that the filing of Form 1024 will not relieve an organization of the requirement to submit the section 506 notification.

EXCISE TAX

This notice provides rules for claimants to make one-time claims for the retroactively extended 2015 biodiesel mixture and alternative fuel excise tax credits. It also provides guidance for claimants to claim the other retroactively extended fuel credits for 2015, including the alternative fuel mixture excise tax credit.

ADMINISTRATIVE

This notice provides rules for claimants to make one-time claims for the retroactively extended 2015 biodiesel mixture and alternative fuel excise tax credits. It also provides guidance for claimants to claim the other retroactively extended fuel credits for 2015, including the alternative fuel mixture excise tax credit.

This notice relates to alternative methods of compliance with the rules under sections 853 and 905(c) as they apply when a regulated investment company (RIC) receives a refund of a foreign tax that when paid by the RIC, was treated as paid by the RIC’s shareholders under section 853(b)(2) because an election was made under section 853(a). The notice describes regulations that the Treasury Department and IRS intend to issue which will allow a netting procedure that, if applied by the RICs, will greatly reduce the administrative costs and burdens on the U.S. government, RICs, and the RICs’ shareholders. The notice also provides guidelines for RICs wishing to obtain closing agreements relating to tax consequences arising from the receipt of such refunds.

This notice provides the maximum vehicle values for use with the special valuation rules under regulation section 1.61–21(d) and (e) for 2016. These values are adjusted for inflation and must be adjusted annually by reference to the Consumer Price Index.



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