This procedure publishes the amounts of unused housing credit carryovers allocated to qualified states under section 42(h)(3)(D) of the Code for calendar year 2019.

This document contains proposed regulations related to the Internal Revenue Code (Code), which allows a State (or its agency or instrumentality) to establish and maintain a tax-advantaged savings program under which contributions may be made to an ABLE account for the purpose of paying for the qualified disability expenses of the designated beneficiary of the account. The affected Code section was amended by the Tax Cuts and Jobs Act, signed into law on December 22, 2017. The Tax Cuts and Jobs Act allows certain designated beneficiaries to contribute a limited amount of compensation income to their own ABLE accounts.

This notice announces that, following the expiration of the temporary regulations under section 385, taxpayers may rely on the notice of proposed rulemaking cross-referencing the temporary regulations.

The proposed regulations provide guidance on the tax consequences of the phased elimination of interbank offered rates (IBORs) that is expected to occur in the United States and many foreign countries. The proposed regulations generally provide that modifying a debt instrument, derivative, or other contract to replace an IBOR-referencing rate (or to revise fallback provisions in anticipation of the elimination of an IBOR) is not treated as a realization event for purposes of section 1001. The proposed regulations also adjust other tax rules, such as the OID and REMIC rules, to minimize the collateral consequences of the elimination of IBORs.

This Revenue Ruling provides guidance on the tax treatment of virtual currency hard forks. This Revenue Ruling provides that a hard fork not followed by an airdrop of units of a new cryptocurrency does not result in gross income to owners of the original cryptocurrency. This Revenue Ruling further provides that a hard fork followed by an airdrop of units of a new cryptocurrency results in gross income to the recipients of units of new cryptocurrency from the airdrop.

26 CFR 1.61-1: Gross income.

(Also §§ 61, 451, 1011.)

This document contains final regulations concerning how partnership liabilities are allocated for disguised sale purposes. The regulations replace existing temporary regulations with final regulations that were in effect prior to the temporary regulations. These regulations affect partnerships and their partners.

This document contains final regulations addressing when certain obligations to restore a deficit balance in a partner’s capital account are disregarded under section 704 of the Internal Revenue Code (Code), when partnership liabilities are treated as recourse liabilities under section 752, and how bottom dollar payment obligations are treated under section 752. These final regulations provide guidance necessary for a partnership to allocate its liabilities among its partners. These regulations affect partnerships and their partners.