This document contains proposed regulations under section 385 of the Internal Revenue Code (Code) that would authorize the Commissioner to treat certain related party interests in a corporation as indebtedness in part and stock in part for federal tax purposes, and establish threshold documentation requirements that must be satisfied in order for certain related party interests in a corporation to be treated as indebtedness for federal tax purposes. The proposed regulations also would treat as stock certain related party interests that otherwise would be treated as indebtedness for federal tax purposes. The proposed regulations generally affect corporations that issue purported indebtedness to related corporations or partnerships.

This revenue procedure provides an updated list of countries with which the IRS and Treasury have determined that it is appropriate to have an automatic exchange relationship with respect to the bank deposit interest information collected under Sections 1.6049–4(b)(5) and 1.6049–8 of the Income Tax Regulations. This revenue procedure is a March 2016 supplement to Rev. Proc. 2014–64, 2014–53 I.R.B. 1022, which was last supplemented by Rev. Proc. 2015–50, 2015–42 I.R.B 583 in September 2015.

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).