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IRB 2016-36

Table of Contents
(Dated September 6, 2016)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2016-36. 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, 7872, and other sections of the Code, tables set forth the rates for September 2016.

This revenue procedure provides the national monthly average premium for a bronze-level qualified health plan (NABP) available through Marketplaces in 2016. The NABP is the maximum monthly individual shared responsibility payment under section 5000A for nonexempt individuals who do not have minimum essential coverage for a month.

This revenue procedure provides safe harbor conditions under which a management contract does not result in private business use of property financed with governmental tax-exempt bonds under section 141(b) of the Internal Revenue Code or cause the modified private business use test for property financed with qualified 501(c)(3) bonds under section 145(a)(2)(B) to be met.

Section 148 imposes yield restriction and rebate requirements on issuers of tax-exempt bonds and other tax-advantaged bonds. These final regulations under section 148 consolidate and finalize proposed regulations published in 2007 and 2013. The final regulations include numerous, independent, technical amendments to various topics in the regulations under section 148. Generally, the final regulations simplify certain provisions, make certain provisions more administrable, resolve certain technical issues, and address certain market developments. Specific topics addressed in the final regulations include, among other things, working capital financings, qualified hedges, and valuation of investments.

Section 301 of James Zadroga 9/11 Health and Compensation Act of 2010, Public Law 111–347 (124 Stat. 3623) added section 5000C to the Internal Revenue Code that imposes a 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. These final regulations provide guidance to U.S. government acquiring agencies and foreign persons to determine what goods or services are subject to the section 5000C; and how to remit the 2 percent tax by U.S. government acquiring agencies or foreign persons, if the section 5000C tax is applicable.

ESTATE TAX

These proposed regulations provide additional guidance under section 2704, which contains special rules for valuing interests in corporations and partnerships transferred within the family, for estate, gift and generation-skipping transfer (GST) tax purposes. The proposed regulations add a new section to address restrictions on the liquidation of an individual interest in a family controlled entity and the effect of small interests held by persons who are not members of the family. The effect of these revisions is to disregard restrictions that reduce the value of the interest for tax purposes, but do not reduce the value of the interest to the family-member recipient.

GIFT TAX

These proposed regulations provide additional guidance under section 2704, which contains special rules for valuing interests in corporations and partnerships transferred within the family, for estate, gift and generation-skipping transfer (GST) tax purposes. The proposed regulations add a new section to address restrictions on the liquidation of an individual interest in a family controlled entity and the effect of small interests held by persons who are not members of the family. The effect of these revisions is to disregard restrictions that reduce the value of the interest for tax purposes, but do not reduce the value of the interest to the family-member recipient.

EXCISE TAX

Section 301 of James Zadroga 9/11 Health and Compensation Act of 2010, Public Law 111–347 (124 Stat. 3623) added section 5000C to the Internal Revenue Code that imposes a 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. These final regulations provide guidance to U.S. government acquiring agencies and foreign persons to determine what goods or services are subject to the section 5000C; and how to remit the 2 percent tax by U.S. government acquiring agencies or foreign persons, if the section 5000C tax is applicable.

TAX CONVENTIONS

Section 301 of James Zadroga 9/11 Health and Compensation Act of 2010, Public Law 111–347 (124 Stat. 3623) added section 5000C to the Internal Revenue Code that imposes a 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. These final regulations provide guidance to U.S. government acquiring agencies and foreign persons to determine what goods or services are subject to the section 5000C; and how to remit the 2 percent tax by U.S. government acquiring agencies or foreign persons, if the section 5000C tax is applicable.

ADMINISTRATIVE

This document contains proposed amendments to the regulations that provide user fees for installment agreements. The proposed amendments affect taxpayers who wish to pay their liabilities through installment agreements. This document also provides a notice of public hearing on these proposed amendments to the regulations.



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