The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pamphlet form as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.

This notice describes the manner in which taxpayers notify the Internal Revenue Service of revocation of an election to aggregate or disaggregate certain church-related organizations from treatment as a single employer under section 414(c)(2)(C) and (D). Churches and church-related organizations are allowed to make elections to aggregate or disaggregate for this purpose under section 414(c)(2)(C) and (D), which were added to the Code by section 336(a) of the Protecting Americans from Tax Hikes Act of 2015 (Public Law 114–113 (129 Stat. 2242 (2015)) (PATH Act). This notice also requests comments with respect to potential guidance on certain other issues raised by PATH Act provisions related to church plans.

This document contains proposed regulations implementing section 951A of the Internal Revenue Code. Section 951A was added to the Internal Revenue Code by the Tax Cuts and Jobs Act, Pub. L. 115–97 (2017), which was enacted on December 22, 2017. This document also contains proposed regulations under sections 951, 1502, and 6038. These proposed regulations would affect United States shareholders of controlled foreign corporations.

The purpose of this revenue procedure is to provide procedures for taxpayers seeking private letter rulings regarding the satisfaction under section 361(b)(3) or (c)(3) or assumption under section 357 of debt of a distributing corporation pursuant to a transaction described by §§ 355 and 368(a)(1)(D). Certain information and representations are required to be submitted with such taxpayers’ submissions.