These proposed regulations amend regulations under sections 165 and 7508A, interpreting new section 7508A(d) relating to mandatory postponements of time to perform time-sensitive tax acts by reason of a federally declared disaster, and clarifying the definition of federally declared disaster under section 165(i)(5). Under section 7508A(a), the Secretary has discretion to determine which taxpayers are affected by a federally declared disaster and to specify both the time-sensitive acts that are postponed and a period of time that may be disregarded, up to one year, in determining whether such acts are timely performed. The proposed regulations clarify that the phrase “in the same manner as a period specified under [section 7508A(a)]” in section 7508A(d)(1) means that the time-sensitive acts postponed for the mandatory 60-day period are those determined by the Secretary under section 7508A(a). The proposed regulations further provide that the mandatory 60-day period will only apply if the Secretary bases his discretionary determination on a disaster declaration that specifies an incident date. The proposed regulations also clarify that the mandatory 60-day period cannot exceed the one-year limitation provided under section 7508A(a).

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for January 2021 used under § 417(e)(3)(D), the 24-month average segment rates applicable for January 2021, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effective January 1, 2021.

26 CFR 1.401(l)-1: Permitted disparity in employer-provided contributions or benefits.

These proposed regulations provide guidance under sections 1297 and 1298, including rules regarding the treatment of certain income received or accrued by a foreign corporation and assets held by a foreign corporation for purposes of section 1297 and rules on whether a foreign corporation is engaged in the active conduct of an insurance business for purposes of section 1297(b)(2)(B). The proposed regulations also include rules addressing the treatment of qualified improvement property under the alternative depreciation system for purposes of the global intangible low-taxed income and the foreign-derived intangible income provisions.

This revenue procedure extends to September 30, 2021, the expiration dates relevant to the application of the safe harbors in Rev. Proc. 2020-26, 2020-18 I.R.B. 753, and Rev. Proc. 2020-34, 2020-26 I.R.B. 990.

26 CFR 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability.

(Also: Part I, §§ 860D, 860F, 860G, 1001; 1.856-6, 1.860G–2, 1.1001–3, 301.7701–2, 301.7701-3, 301.7701-4.)

These final regulations provide guidance under sections 1291, 1297, and 1298, regarding the determination of ownership in a passive foreign investment company and the treatment of certain income received or accrued by a foreign corporation and assets held by a foreign corporation for purposes of section 1297. The final regulations also provide guidance regarding the exclusion from passive income under section 1297(b)(2)(B) for income derived by a qualifying insurance corporation in the active conduct of an insurance business.

26 CFR 1.1291-1; 1.1297-1; 1.1297-2; 1.1297-4; 1.1297-6; 1.1297-6; 1.1298-2; 1.1298-4

This document contains final regulations that provide additional guidance regarding the limitation on the business interest expense deduction limitation to reflect changes made by the Tax Cuts and Jobs Act and the Coronavirus Aid, Relief, and Economic Security Act. The final regulations provide guidance regarding which taxpayers and trades or businesses are subject to the limitation, and how the limitation applies in consolidated group, partnership, international, and other contexts.

Section 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains. An applicable partnership interest is an interest in a partnership that is transferred to or held by a taxpayer in connection with the performance of substantial services by the taxpayer, or any other related person, in any applicable trade or business. The final regulations also amend existing regulations on holding periods to clarify the holding period of a partner’s interest in a partnership that includes an applicable partnership interest and/or a profits interest.

26 CFR 1.1061-0: Table of contents; 26 CFR 1.1061-1; 26 CFR 1.1061-2; 26 CFR 1.1061-3; 26 CFR 1.1061-4; 26 CFR 1.1061-5; 26 CFR 1.1061-6