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IRB 2018-06

Table of Contents
(Dated February 5, 2018)
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This is the table of contents of Internal Revenue Bulletin IRB 2018-06. 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

The notice permits qualifying withholding agents to apply the transition rules in Notice 2010–46 for calendar years 2018 and 2019.

This notice provides additional guidance for determining amounts included in gross income by a United States shareholder under section 951(a)(1) by reason of section 965 of the Internal Revenue Code as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018”, P.L. 115–97, which was enacted on December 22, 2017.

This revenue procedure provides safe harbors that taxpayers may use to value stock for purposes of the continuity of interest (COI) requirement under section 1.368–1(e). If the conditions set forth in the revenue procedure are met, taxpayers may use the average of the daily volume weighted average prices, the average of the average high-low daily prices, or the average of the daily closing prices of stock trading on certain stock exchanges in order to determine whether the COI requirement has been satisfied under the signing date rule or the closing date rule.

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 February 2018.



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