<!-- TTST:[]: TTC:[]: TTSC:[]: TTT:[IRB]: TTS:[]: TTCP:[IRB 2016-51]: TTCI:[Highlights]: TTB:[]: TTA:[]: TTD:[]: -->

IRB 2016-51

Table of Contents
(Dated December 19, 2016)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2016-51. 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.

View the original PDF version of this Internal Revenue Bulletin

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

These proposed regulations relate to the establishment of dollar-value, last-in, first-out (LIFO) inventory pools by certain taxpayers that use the inventory price index computation (IPIC) pooling method. The proposed regulations provide rules regarding the proper pooling of manufactured or processed goods and wholesale or retail (resale) goods.

Interest rates: underpayments and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning January 1, 2017, will be 4 percent for overpayments (3 percent in the case of a corporation), 4 percent for underpayments, and 6 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 1.5 percent.

This notice provides that the IRS will not assert that cash payments an employer makes to § 170(c) organizations (in exchange for vacation, sick, or personal leave that its employees elect to forgo) constitute gross income or wages of the employees under certain circumstances relating to Hurricane Matthew.

This notice provides guidance on section 45R of the Internal Revenue Code (Code) for certain small employers that cannot offer a qualified health plan (QHP) through a Small Business Health Options Program (SHOP) Exchange because the employer's principal business address is in a county in which a QHP through a SHOP Exchange will not be available for the 2016 calendar year (the counties, which are listed in the notice, are all in Wisconsin). With respect to those employers, this notice provides transition relief allowing employers to claim the credit by satisfying the pre-2014 rules.

The notice provides phased-in the application of the section 871(m) dividend equivalent regulations that were finalized in September of 2015. The notice provides that the section 871(m) regulations: (1) only apply to delta-one transactions in calendar year 2017, and (2) will apply to non-delta-one transactions beginning in calendar year 2018. The notice also provides phased-in enforcement of the section 871(m) regulations, including the qualified derivatives dealer rules.

EMPLOYEE PLANS

These proposed regulations provide guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. The proposed regulations would provide guidance on changes made by the Pension Protection Act of 2006 and would provide other modifications to these rules as well.

ESTATE TAX

Final regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035(a)(1) or (2) regarding the value of property included in a decedent’s gross estate for federal estate tax purposes before June 30, 2016, need not have done so until June 30, 2016. These final regulations are applicable to executors and other persons who file federal estate tax returns required by section 6018(a) or (b) after July 31, 2015.

ADMINISTRATIVE

The proposed regulations implement Congress's recent changes to the paid preparer due diligence statute, expanding the due diligence statute to include claims of the child tax credit, the additional child tax credit, and/or the American opportunity tax credit, and providing that the amount of the penalty will be adjusted for inflation.

The revenue procedure sets forth the loss payment patterns and discount factors for accident year 2016 for purposes of § 846 of the Internal Revenue Code.

This revenue procedure prescribes the salvage discount factors for the 2016 accident year. These factors must be used to compute discounted estimated salvage recoverable under § 832 of the Internal Revenue Code.

This document contains the amendments to the regulations that provide user fees for installment agreements. The amendments affect taxpayers who wish to pay their liabilities through installment agreements.

The final and temporary regulations implement Congress's recent changes to the paid preparer due diligence statute, expanding the due diligence statute to include claims of the child tax credit, the additional child tax credit, and/or the American opportunity tax credit, and providing that the amount of the penalty will be adjusted for inflation.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.