Legal Status
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- Documents
- Public Inspection
Topic
- Reporting and recordkeeping requirements 14
- Income taxes 13
- Excise taxes 5
- Estate taxes 4
- Gift taxes 4
Section
- Money 18
- Business & Industry 17
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Publication Date
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Type
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Agency
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Guidance on Passive Foreign Investment Companies and the Treatment of Qualified Improvement Property Under the Alternative Depreciation System for Purposes of Sections 250(b) and 951A(d)
This document contains proposed regulations regarding the determination of whether a foreign corporation is treated as a passive foreign investment company (``PFIC'') for purposes of the Internal Revenue Code (``Code''). The proposed regulations also provide guidance regarding the treatment of income and assets of a qualifying insurance...
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Mandatory 60-Day Postponement of Certain Tax-Related Deadlines by Reason of a Federally Declared Disaster
This document contains proposed regulations relating to the new mandatory 60-day postponement of certain time-sensitive tax-related deadlines by reason of a Federally declared disaster. This document also contains proposed regulations clarifying the definition of ``Federally declared disaster.'' These proposed regulations affect individuals who...
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User Fee for Estate Tax Closing Letter
This document contains proposed regulations establishing a new user fee for authorized persons who wish to request the issuance of IRS Letter 627, also referred to as an estate tax closing letter. The Independent Offices Appropriations Act of 1952 authorizes charging user fees in appropriate circumstances. The proposed regulations affect persons...
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Treatment of Special Enforcement Matters
This document contains proposed regulations to except certain partnership-related items from the centralized partnership audit regime that was created by the Bipartisan Budget Act of 2015, and sets forth alternative rules that will apply. The centralized partnership audit regime does not apply to a partnership-related item if the item involves a...
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IRS Review of Regulatory and Other Relief To Support Economic Recovery
On May 19, 2020, the President signed Executive Order 13924, Executive Order On Regulatory Relief to Support Economic Recovery, to direct agencies to consider principles of fairness in administrative enforcement and adjudication and to consider rescinding, modifying, or waiving any regulations and other requirements that may inhibit the ongoing...
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Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income
This document contains proposed regulations relating to the foreign tax credit, including guidance on the disallowance of a credit or deduction for foreign income taxes with respect to dividends eligible for a dividends-received deduction; the allocation and apportionment of interest expense, foreign income tax expense, and certain deductions of...
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Additional First Year Depreciation Deduction
This document withdraws a portion of a notice of proposed rulemaking published in the Federal Register on September 24, 2019. The withdrawn portion relates to the extent to which a partner is deemed to have a depreciable interest in property held by a partnership.
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Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
Elsewhere in this issue of the Federal Register, the IRS is issuing temporary regulations regarding coverage of preventive health services to implement section 3203 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which shortens the timeframe under which non-grandfathered group health plans and health insurance issuers...
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Section 42, Low-Income Housing Credit Average Income Test Regulations
This document contains proposed regulations setting forth guidance on the average income test under section 42(g)(1)(C) of the Internal Revenue Code (Code) for purposes of the low-income housing credit. These proposed regulations affect owners of low-income housing projects, tenants in those projects, and State or local housing credit agencies...
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Ownership Attribution Under Section 958 for Purposes of Sections 367(a) and 954(c)(6)
This document contains proposed regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation...
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Small Business Taxpayer Exceptions Under Sections 263A, 448, 460 and 471; Correction
This document contains a correction to a notice of proposed rulemaking (REG-132766-18) that was published in the Federal Register on August 5, 2020. The proposed regulations to implement legislative changes to sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) that simplify the application of those tax accounting provisions for...
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Certain Medical Care Arrangements; Hearing
This document provides a notice of public hearing on proposed regulations relating to section 213 of the Internal Revenue Code (Code) regarding the treatment of amounts paid for certain medical care arrangements, including direct primary care arrangements, health care sharing ministries, and certain government sponsored health care programs.
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Limitation on Deduction for Business Interest Expense; Allocation of Interest Expense by Passthrough Entities; Dividends Paid by Regulated Investment Companies; Application of Limitation on Deduction for Business Interest Expense to United States Shareholders of Controlled Foreign Corporations and to Foreign Persons With Effectively Connected Income
This notice of proposed rulemaking provides rules concerning the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the provisions commonly known as the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, and the Coronavirus Aid, Relief, and Economic Security Act, which was...
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Coordination of Extraordinary Disposition and Disqualified Basis Rules
This document contains proposed regulations under sections 245A and 951A of the Internal Revenue Code (the ``Code'') that coordinate the extraordinary disposition rule under section 245A of the Internal Revenue Code (the ``Code'') with the disqualified basis rule under section 951A of the Code. This document also contains proposed regulations...
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Rollover Rules for Qualified Plan Loan Offset Amounts
This document sets forth proposed regulations relating to amendments made to section 402(c) of the Internal Revenue Code (Code) by section 13613 of the Tax Cuts and Jobs Act, Public Law 115-97 (131 Stat. 2054) (TCJA). Section 13613 of TCJA provides an extended rollover period for a qualified plan loan offset, which is a type of plan loan offset....
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Guidance Under Section 1061
This document contains proposed regulations that provide guidance under section 1061 of the Internal Revenue Code (Code). 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...
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Guidance Involving Hybrid Arrangements and the Allocation of Deductions Attributable to Certain Disqualified Payments Under Section 951A (Global Intangible Low-Taxed Income); Correction
This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on April 8, 2020. The proposed regulations that adjust hybrid deduction accounts to take into account earnings and profits of a controlled foreign corporation that are included in income by a United States shareholder.
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Certain Non-Government Persons Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) Contractor
This document withdraws a notice of proposed rulemaking (REG- 132434-17) published in the Federal Register on March 28, 2018, which contained proposed regulations that addressed the participation of persons described under section 6103(n) of the Code in the interview of a summoned witness and excluded certain non-government attorneys from...