This notice under § 7508A of the Internal Revenue Code postpones the beginning of the lookback periods under § 6511 for certain taxpayers to file a claim for refund. The affected taxpayers are those that had tax returns due from April 15, 2020, to July 15, 2020, or from April 15, 2021, to May 17, 2021, and due to the COVID-19 pandemic, those due dates were postponed by Notice 2020-23 or Notice 2021-21 to July 15, 2020 or May 17, 2021, respectively. Those 2020 and 2021 notices did not postpone the beginning of the lookback periods under § 6511 for claiming refunds related to those returns. This notice aligns the lookback periods with the postponed 2020 and 2021 tax return filing due dates.

The final regulations amend the rules for filing certain returns and statements electronically to reflect changes made by the Taxpayer First Act of 2019 and to promote electronic filing.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for February 2023 used under § 417(e)(3)(D), the 24-month average segment rates applicable for February 2023, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

These proposed regulations provide rules relating to the use of forfeitures in qualified retirement plans, including a deadline for the use of forfeitures in defined contribution plans, and clarify that forfeitures arising in any defined contribution plan (including in a money purchase pension plan) may be used for one or more of the following purposes, as specified in the plan: (1) to pay plan administrative expenses, (2) to reduce employer contributions under the plan, or (3) to increase benefits in other participants’ accounts in accordance with plan terms. The proposed regulations would require that plan administrators use or allocate forfeitures no later than 12 months after the close of the plan year in which the forfeitures are incurred. The proposed regulations also update rules relating to the use of forfeitures in defined benefit plans to reflect statutory changes enacted after the existing regulations were promulgated.

Issue 1:

Nonacquiescence to the court’s conclusion that the parties’ failure to report the transactions fully or consistently should not be a major factor in a decision whether to allow a taxpayer to disavow the form of its transactions and also to the standard the court applied to allow petitioner to disavow its form in this case.

Issue 2:

Nonacquiescence to the court’s determination that the fair market value of a “Deferred Payment Right” (as described therein) for purposes of section 351(b)(1) is not equal to its issue price.

This document contains final regulations that treat members of a consolidated group as a single United States shareholder in certain cases for purposes of section 951(a)(2)(B) of the Internal Revenue Code.

26 CFR 1.1502-80(j): Special rules for application of section 951(a)(2)(B) to distributions to which section 959(b) applies