This notice solicits public comments recommending guidance projects that should be included in the 2019-2020 Priority Guidance Plan.

This revenue procedure provides for a limited expansion of the determination letter program with respect to individually designed plans. This revenue procedure also provides for a limited extension of the remedial amendment period under § 401(b) of the Internal Revenue Code and Rev. Proc. 2016-37 under specified circumstances, and for special sanction structures that apply to certain plan document failures discovered by the IRS during the review of a plan submitted for a determination letter pursuant to this revenue procedure.

This revenue ruling provides guidance on the application of subchapters C and S of chapter 1 of subtitle A of the Internal Revenue Code (Code) to cash distributions made in redemption of the stock of C corporations formerly classified as S corporations and during the post-termination transition period as defined under section 1377(b) of the Code. Specifically, the revenue ruling holds that to the extent a corporation makes such a cash distribution that is subject to section 301 of the Code by reason of section 302(d) of the Code, the cash distribution should reduce the corporation’s accumulated adjustments account (within the meaning of section 1368(e) of the Code) to the extent of the proceeds of the redemption pursuant to section 1368 of the Code.

26 CFR 1.1368-1: Distributions by S corporations (Also: §§ 301, 302, 1362, 1367, 1371, 1377, 26 CFR 1.1368-2)

The notice publishes the inflation adjustment factor for the carbon oxide sequestration credit under § 45Q for calendar year 2019. Also, the notice includes a statement of the amount of qualified carbon oxide that has been taken into account by taxpayers filing an annual report pursuant to section 6 of Notice 2009-83, 2009-2 C.B. 588.