This notice announces that the Treasury Department and the IRS intend to issue regulations under new section 1446(f) regarding the disposition of a partnership interest that is not publicly traded. This notice also provides interim guidance that taxpayers may rely on pending the issuance of regulations.

This notice impacts U.S. multinational enterprise groups that are required to file a Form 8975 and Schedule A (Form 8975) (Country-by-Country Report) (i.e., those that have more than $850M in revenue in the prior reporting period) and that have more than 50 percent of their revenues attributable to contracts with the Department of Defense or other U.S. governmental intelligence or security agencies. Such specified national security contractors may file their Country-by-Country Report in the modified manner described in the notice.

These proposed regulations will narrow the scope of the current summons interview regulations by excluding certain non-government attorneys from receiving summoned books, papers, records, or other data, or from participating in the interview of a witness summoned by the IRS to provide testimony under oath. An attorney who is not an officer or employee of the United States may not be hired by the IRS to perform these activities unless the attorney is hired by the IRS as a specialist in foreign, state, or local law, including tax law, or in non-tax substantive law that is relevant to an issue in the examination, such as patent law, property law, or environmental law, or is hired for knowledge, skills, or abilities other than providing legal services as an attorney.

Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

This notice provides additional guidance regarding the implementation 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 notice announces that the Department of the Treasury and the Internal Revenue Service (IRS) intend to issue proposed regulations providing guidance to assist taxpayers in complying with section 163(j) of the Internal Revenue Code (Code), as amended on December 22, 2017, 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 (the Act). This notice further describes certain of the rules that those proposed regulations will include to provide taxpayers with interim guidance as more comprehensive guidance is developed. The rules described in this notice apply only for purposes of determining the limitation on deductions for interest expense under section 163(j), as amended by the Act.

This notice announces that the Treasury Department and the IRS intend to issue regulations under new section 1446(f) regarding the disposition of a partnership interest that is not publicly traded. This notice also provides interim guidance that taxpayers may rely on pending the issuance of regulations.

Fringe benefits aircraft valuation formula. For purposes of section 1.61–21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the first half of 2018 are set forth.

These final regulations provide rules addressing the allocation of the credit for increasing research activities to corporations and trades or businesses under common control. These final regulations also contain rules relating to the allocation of the railroad track maintenance credit and the election for a reduced research credit.

This notice announces that the Treasury Department and the IRS intend to issue regulations under new section 1446(f) regarding the disposition of a partnership interest that is not publicly traded. This notice also provides interim guidance that taxpayers may rely on pending the issuance of regulations.