Proposed regulations would treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Code.

This revenue procedure provides the List of Automatic Changes to which the automatic change procedures in Rev. Proc. 2015–13, 2015–5 I.R.B. 419, as clarified and modified by Rev. Proc. 2015–33, 2015–24 I.R.B. 1067, and as modified by Rev. Proc. 2016–1, 2016–1 I.R.B. 1, (or successor) apply. The definitions in section 3 of Rev. Proc. 2015–13 apply to this revenue procedure. Rev. Proc. 2015–14 is superseded in part.

This document revises Rev. Proc. 2009–14, which outlines the procedures to resolve issues through a pre-filing agreement (PFA). The Rev. Proc. (1) expands the scope of a PFA to include issues relating to changes in methods of accounting requested pursuant to the automatic consent procedures; (2) reflects LBI's new structure; (3) clarifies or updates procedures for fling PFA requests; and (4) increases the user fee for PFAs from $50,000 to $134,300 for requests submitted on or after the date that is 30 days after the Rev. Proc. is released, to $218,600 for requests submitted on or after January 1, 2017.

The revenue procedure provides that certain contributions that money market funds receive from sponsors may be excluded from the distribution requirements of § 852(a) of the Internal Revenue Code but are included in investment company taxable income for purposes of § 852(b).

The notice provides alternative diversification requirements under section 817(h) of the Internal Revenue Code for a segregated asset account that invests in a money market fund (MMF) that is a government MMF.

Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer defined benefit pension plans in critical and declining funded status.

Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer defined benefit pension plans in critical and declining funded status.

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).

Generally, for federal income tax purposes, a business entity that has a single owner and is not a corporation is disregarded as an entity separate from its owner (a disregarded entity). However, for purposes of employment taxes, a disregarded entity is treated as a corporation, except that the owner of a disregarded entity who is treated as a sole proprietor for income tax purposes remains subject to self-employment taxes. The current regulations do not explicitly address situations in which the owner of a disregarded entity is a partnership. These proposed regulations address this issue by clarifying that the rule that a disregarded entity is treated as a corporation for employment tax purposes does not alter the self-employment tax treatment of any individuals who are partners in the partnership that owns a disregarded entity.

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 requires the establishment of a voluntary certification program for professional employer organizations. A professional employer organization, sometimes referred to as an employee leasing company, is an organization that enters into an agreement with a client to perform some or all of the federal employment tax withholding, reporting, and payment functions related to workers performing services for the client. Being certified by the IRS as a certified professional employer organization (CPEO) has certain federal employment tax consequences for both the CPEO and its customers and clients. These proposed regulations set forth the federal employment tax liabilities and other obligations of persons certified by the IRS as CPEOs.

Generally, for federal income tax purposes, a business entity that has a single owner and is not a corporation is disregarded as an entity separate from its owner (a disregarded entity). However, for purposes of employment taxes, a disregarded entity is treated as a corporation, except that the owner of a disregarded entity who is treated as a sole proprietor for income tax purposes remains subject to self-employment taxes. The current regulations do not explicitly address situations in which the owner of a disregarded entity is a partnership. These temporary regulations address this issue by clarifying that the rule that a disregarded entity is treated as a corporation for employment tax purposes does not alter the self-employment tax treatment of any individuals who are partners in the partnership that owns a disregarded entity.

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 requires the establishment of a voluntary certification program for professional employer organizations. A professional employer organization, sometimes referred to as an employee leasing company, is an organization that enters into an agreement with a client to perform some or all of the federal employment tax withholding, reporting, and payment functions related to workers performing services for the client. Being certified by the IRS as a certified professional employer organization (CPEO) has certain federal employment tax consequences for both the CPEO and its customers and clients. These final and temporary regulations describe the requirements a person must satisfy in order to become and remain a CPEO.

Generally, for federal income tax purposes, a business entity that has a single owner and is not a corporation is disregarded as an entity separate from its owner (a disregarded entity). However, for purposes of employment taxes, a disregarded entity is treated as a corporation, except that the owner of a disregarded entity who is treated as a sole proprietor for income tax purposes remains subject to self-employment taxes. The current regulations do not explicitly address situations in which the owner of a disregarded entity is a partnership. These proposed regulations address this issue by clarifying that the rule that a disregarded entity is treated as a corporation for employment tax purposes does not alter the self-employment tax treatment of any individuals who are partners in the partnership that owns a disregarded entity.

Generally, for federal income tax purposes, a business entity that has a single owner and is not a corporation is disregarded as an entity separate from its owner (a disregarded entity). However, for purposes of employment taxes, a disregarded entity is treated as a corporation, except that the owner of a disregarded entity who is treated as a sole proprietor for income tax purposes remains subject to self-employment taxes. The current regulations do not explicitly address situations in which the owner of a disregarded entity is a partnership. These temporary regulations address this issue by clarifying that the rule that a disregarded entity is treated as a corporation for employment tax purposes does not alter the self-employment tax treatment of any individuals who are partners in the partnership that owns a disregarded entity.

Proposed regulations would treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Code.

This document revises Rev. Proc. 2009–14, which outlines the procedures to resolve issues through a pre-filing agreement (PFA). The Rev. Proc. (1) expands the scope of a PFA to include issues relating to changes in methods of accounting requested pursuant to the automatic consent procedures; (2) reflects LBI's new structure; (3) clarifies or updates procedures for fling PFA requests; and (4) increases the user fee for PFAs from $50,000 to $134,300 for requests submitted on or after the date that is 30 days after the Rev. Proc. is released, to $218,600 for requests submitted on or after January 1, 2017.