While current law is clear that changes in conversion ratios in convertible instruments may result in deemed distributions under section 305, ambiguities exist whether the deemed distribution is of shares of stock or rights to acquire stock, and concerning the amount and timing of these deemed distributions. These proposed regulations clarify that the deemed distribution is of rights to acquire stock, and the amount and timing of the deemed distribution. Guidance is also provided to withholding agents regarding their withholding obligations under sections 860G, 861, 1441, 1461, 1471, and 1473 , as well as information reporting guidance for such deemed distributions under section 6045B.

This document contains proposed regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The regulations are issued by cross-reference to temporary regulations in TD 9761.

This revenue procedure provides indexing adjustments for certain provisions under sections 36B and 5000A of the Internal Revenue Code. In particular, it updates the Applicable Percentage Table in § 36B(b)(3)(A)(i) to provide the Applicable Percentage Table for 2017 that is used to calculate an individual’s premium tax credit. This revenue procedure also updates the required contribution percentage in § 36B(c)(2)(C)(i)(II) for plan years beginning after calendar year 2016. The percentage is used to determine whether an individual is eligible for affordable employer-sponsored minimum essential coverage under § 36B. Additionally, this revenue procedure cross-references the required contribution percentage under § 5000A(e)(1)(A) for plan years beginning after calendar year 2016, as determined under guidance issued by the Department of Health and Human Services. The percentage is used to determine whether an individual is eligible for an exemption from the individual shared responsibility payment because of a lack of affordable minimum essential coverage.

The Notice provides that the Service has designated, under I.R.C. section 7502(f), eight new delivery services as designated Private Delivery Services that qualify for the timely mailing treated as timely filing/paying rule of section 7502.

The announcement states that certain provisions of proposed regulations that were published on January 29, 2016 (81 FR 4976) pertaining to the nondiscrimination rules applicable to qualified retirement plans will be withdrawn.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2016 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2016, 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 procedure provides issuers of qualified mortgage bonds (QMBs) and qualified mortgage credit certificates (MCCs) with average area purchase price safe harbors for statistical areas in the United States and with a nationwide average purchase price for residences in the United States for purposes of the QMB rules under section 143 of the Code and the MCC rules under section 25. Rev. Proc. 2015–31 obsoleted in part.

The Notice provides that the Service has designated, under I.R.C. section 7502(f), eight new delivery services as designated Private Delivery Services that qualify for the timely mailing treated as timely filing/paying rule of section 7502.