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This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). This twenty-fourth report describes the experience, structure, and activities of the APMA Program during calendar year 2022.
This notice of proposed rulemaking provides guidance related to sections 4661, 4662, 4671, and 4672 of the Internal Revenue Code, collectively referred to as the Superfund chemical taxes. Section 4661(a) imposes an excise tax on the sale or use of “taxable chemicals” by manufacturers, producers, or importers. Section 4671(a) imposes an excise tax on the sale or use of “taxable substances” by importers. The Superfund chemical taxes previously expired on December 31, 1995, but were reinstated with certain modifications, effective July 1, 2022, by section 80201 of the Infrastructure Investment and Jobs Act (IIJA), Public Law 117-58, 135 Stat. 429 (November 15, 2021).
This Notice announces that when proposed regulations under section 903 (REG-112096-22) are finalized, the Treasury Department and the IRS intend to extend the transition period for the single-country exception’s documentation requirement from May 17, 2023 to 180 days after the final regulations are filed with the Federal Register. The single-country exception provides relief from the source-based attribution requirement under section 903 for foreign withholding taxes on royalties paid for the use of intellectual property within the withholding jurisdiction.
This document contains proposed regulations regarding the credit for clean vehicles under section 30D of the Internal Revenue Code (Code). These proposed regulations will affect persons seeking to claim the § 30D credit and qualified manufacturers of the clean vehicles.
Revenue Ruling 2023-2 confirms that the basis adjustment under section 1014 generally does not apply to the assets of an irrevocable grantor trust not included in the deceased grantor’s gross estate for Federal estate tax purposes.
26 CFR 1.1014-1: Basis of Property Acquired from a Decedent
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