This document contains proposed regulations that would update information reporting regulations under section 6033 that are generally applicable to organizations exempt from tax under section 501(a) to reflect statutory amendments and certain grants of reporting relief announced through subregulatory guidance that have been made since the current regulations were adopted, particularly with respect to tax-exempt organizations required to file an annual Form 990 or 990-EZ information return.

These proposed regulations provide guidance under section 382(h) regarding the calculation of built-in gains and losses that are attributable to the period preceding a corporation’s ownership change. Built-in gains and losses affect the amount of losses and deductions that a corporation can claim after an ownership change. The proposed regulations (i) simplify the application of section 382 and provide more certainty to taxpayers in determining built-in gains and losses for section 382(h) purposes, and (ii) ensure that difficult questions regarding the application of Tax Cuts and Jobs Act of 2017 provisions do not unnecessarily complicate application of section 382(h). In particular, the proposed regulations provide general rules and definitions regarding the calculation of net unrealized built-in gains and loss and identification of items that constitute recognized built-in gain or loss.

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 second half of 2019 are set forth.

26 CFR 1.61-21: Taxation of fringe benefits.