This procedure provides specifications for the private printing of red-ink substitutes for the 2019 revisions of certain information returns. This procedure will be reproduced as the next revision of Publication 1179. Rev. Proc. 2018-46 is superseded.

This notice amplifies Notice 2018-48, 2018-28 I.R.B. 9, which lists the population census tracts that the Secretary of the Treasury (Secretary) designated as qualified opportunity zones (QOZs). Specifically, this notice adds two additional census tracts in Puerto Rico that have been designated as QOZs under § 1400Z-1(b)(3) of the Internal Revenue Code (Code).

These proposed regulations provide rules regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. In addition, these proposed regulations contain rules under the global intangible low-taxed income provisions regarding gross income that is subject to a high rate of foreign tax. These proposed regulations would affect United States persons that own stock of foreign corporations through domestic partnerships and United States shareholders of foreign corporations.

These final regulations provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations, including United States shareholders that are members of a consolidated group. These final regulations also contain rules relating to the determination of a United States shareholder’s pro rata share of a controlled foreign corporation’s subpart F income included in the shareholder’s gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income. Finally, these final regulations contain rules relating to certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations.