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IRB 2017-41

Table of Contents
(Dated October 10, 2017)
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This is the table of contents of Internal Revenue Bulletin IRB 2017-41. 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, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2017.

Notice 2017–46 provides guidance for certain foreign financial institutions (FFIs) required to report U.S. taxpayer identification numbers (U.S. TINs) for certain accounts under a Model 1 Intergovernmental Agreement (IGA). If such FFIs comply with the procedures described in this Notice, then the IRS will not consider there is significant noncompliance with the obligations under a Model 1 IGA solely as a result of a failure to report U.S. TINs associated with the FFI's U.S. reportable accounts maintained as of the determination date specified in the applicable Model 1 IGA. Notice 2017–46 also announces that the Department of the Treasury and the IRS intend to amend certain provisions of the temporary regulations under Chapter 3. The amendments would provide limitations on, and a phase-in of, the requirement for certain withholding agents to obtain and report the taxpayer identification number issued by an account holder's jurisdiction of tax residence (Foreign TIN) and, for an account holder that is an individual, the account holder's date of birth. Taxpayers may rely on the provisions of this notice prior to the issuance of the amendments to the temporary Chapter 3 regulations reflecting the notice.

This revenue procedure: (1) introduces an 18-month pilot program expanding the scope of private letter rulings available from the Internal Revenue Service to include rulings on the tax consequences of a distribution of stock, or stock and securities, of a controlled corporation under § 355 of the Internal Revenue Code, (2) provides procedures for taxpayers requesting these letter rulings, and (3) clarifies procedures for taxpayers requesting letter rulings on significant issues relating to these transactions.

The proposed regulation allows the truncation of taxpayer identification numbers on copies of Forms W–2, Wage and Tax Statement, that are furnished to employees. The proposed regulation would amend the existing regulations to specifically allow for truncation on those copies, consistent with the rules regarding truncation in Treas. Reg. section 301.6109–4.

Several provisions of the Code condition tax benefits and impose sanctions on issuers and holders of registration-required obligations that are not issued in registered form. This project defines a registration-required obligation and describes when an obligation is in registered form for purposes of these provisions. The proposed rules update longstanding regulations to account for changes in the operation of debt markets and to account for the repeal of a statutory exception to the definition of registration-required obligation.

EMPLOYEE PLANS

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for September 2017 used under § 417(e)(3)(D), the 24-month average segment rates applicable for September 2017, 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).

EMPLOYMENT TAX

The proposed regulation allows the truncation of taxpayer identification numbers on copies of Forms W–2, Wage and Tax Statement, that are furnished to employees. The proposed regulation would amend the existing regulations to specifically allow for truncation on those copies, consistent with the rules regarding truncation in Treas. Reg. section 301.6109–4.



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