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IRB 2016-15

Table of Contents
(Dated April 11, 2016)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2016-15. 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

Fringe benefits aircraft valuation formula. For purposes of section 1.61–21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the first half of 2016 are set forth.

This notice provides that statements required under section 6035, regarding the basis of property distributed from the estate of a decedent, need not be filed or furnished until June 30, 2016, rather than the current March 31, 2016 deadline.

Notice 2016–28 explains how a State or local government amends the nomination of an empowerment zone to provide for a new termination date of December 31, 2016.

These regulations apply when a corporation that is subject to U.S. income tax acquires loss property tax-free from a liquidating subsidiary, from shareholders or others in a capital contribution, or from another corporation or person in a reorganization, and the loss in the acquired property accrued outside the U.S. tax system. The regulations provide guidance for preventing the importation of loss in such cases by requiring the bases of the assets received to be equal to value.

These regulations finalize without substantive change temporary and proposed regulations promulgated in 2013 that address outbound transfers of stock or securities in certain nonrecognition transactions. First, the regulations finalize modifications to the indirect stock transfer coordination rule, which generally provides that section 367(a) and (d) apply to any assets transferred in an outbound reorganization before the indirect stock transfer rules. The modifications finalize changes to the exceptions to the coordination rule by providing that – under certain conditions – section 367(a) and (d) will not apply to the transferred assets to the extent those assets are re-transferred to a domestic corporation. Second, these regulations finalize rules governing transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. Finally, these regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements.

ESTATE TAX

This notice provides that statements required under section 6035, regarding the basis of property distributed from the estate of a decedent, need not be filed or furnished until June 30, 2016, rather than the current March 31, 2016 deadline.

ADMINISTRATIVE

This revenue procedure updates Rev. Proc. 87.24, 1987–1 C.B. 720, which describes the practices for the administrative appeals process in cases docketed in the United States Tax Court.

This notice provides that statements required under section 6035, regarding the basis of property distributed from the estate of a decedent, need not be filed or furnished until June 30, 2016, rather than the current March 31, 2016 deadline.



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