This revenue procedure provides guidance for taxpayers that hold investments in one or more segregated asset accounts on which variable contracts as defined in section 817 of the Internal Revenue Code are based. The guidance allows taxpayers to elect to treat certain mortgage-backed securities as having deemed issuers for purposes of the diversification requirements of section 817(h).

Notice 2018–84 provides interim guidance clarifying how the suspension of the personal exemption deduction in § 151(d)(5) of the Tax Cuts and Jobs Act applies to certain rules under §§ 36B and 6011 relating to the premium tax credit, and under § 5000A relating to the individual shared responsibility provision. The notice also announces that the Treasury Department and IRS intend to amend the regulations under §§ 36B and 6011 to clarify the application of § 151(d)(5), and that until further guidance is issued the guidance in the notice applies.

This revenue procedure provides guidance for taxpayers that hold investments in one or more segregated asset accounts on which variable contracts as defined in section 817 of the Internal Revenue Code are based. The guidance allows taxpayers to elect to treat certain mortgage-backed securities as having deemed issuers for purposes of the diversification requirements of section 817(h).

Federal rates; adjusted federal rates; adjusted federal long-term rate, the long-term exempt rate, and the blended annual rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for November 2018.

This revenue ruling addresses questions on the application to real property of the “original use” requirement in section 1400Z–2(d)(2)(D)(i)(II) and the “substantial improvement” requirement in section 1400Z–2(d)(2)(D)(i)(II) and 1400Z–2(d)(2)(D)(ii). In addition, this revenue ruling provides guidance on the substantial-improvement requirement with respect to a purchased building located in a qualified opportunity zone.