These final regulations update the due dates and available extensions of time to file certain tax returns and information returns, to reflect statutory requirements set by section 2006 of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 and section 201 of the Protecting Americans from Tax Hikes Act of 2015. Additionally, the regulations remove a provision for electing large partnerships that was made obsolete by section 1101(b)(1) of the Bipartisan Budget Act of 2015. The regulations also delete temporary regulations.

26 CFR Parts 1 and 31

This revenue procedure modifies Rev. Proc. 2020-5 to allow for the new electronic submission process of the Form 1023. This revenue procedure also modifies language related to the submission of written requests of Canadian charities to be listed on the Tax Exempt Organizations Search database or for a determination on private foundation status. Finally, this revenue procedure provides a 90 day transition relief period, during which paper Form 1023 applications will be accepted and processed by EO Determinations.

26 CFR 601.201: Rulings and determination letters.

This revenue ruling clarifies the manner to properly compute the income limits applicable to the low-income housing credit under § 42 of the Internal Revenue Code. The Consolidated Appropriations Act of 2018 added a new minimum set-aside test, the average income test (§ 42(g)(1)(C)), to the existing minimum set-aside tests available to owners of a low-income housing project. This revenue ruling addresses the additional income limits available in the average income test.

(Also Section 7805; 301.7805-1)

These final regulations would finalize the rules in the temporary regulations under REG-127203-15, published January 19, 2017. These final regulations provide rules that address certain transfers of appreciated property by United States persons to partnerships with foreign partners that are related to the transferor. Specifically, these final regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership unless the partnership complies with certain requirement. Those requirements, in turn, are intended to prevent the shifting of tax consequences of precontribution gain to the related foreign partner by ensuring that built-in gain with respect to the contributed property will be subject to U.S. tax.

26 CFR 1.721(c)