This Week's Internal Revenue Bulletin

HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

ADMINISTRATIVE

NOTICE 2019–06, page 353. This notice informs taxpayers that the Department of the Treasury and the Internal Revenue Service intend to propose regulations addressing certain special enforcement matters under section 6241(11). Specifically, this Notice explains that pro-posed rules will be issued that provide the IRS may determine that the centralized partnership audit regime will not apply to adjustments to partnership-related items in certain limited circumstances and that partnerships with a qualified subchapter S subsidiary (QSub) are not eligible to elect out of the centralized partnership audit regime except by applying a rule similar to the rules for S corporations under section 6221(b)(2)(A) to the QSub partner. This notice also requests comments regarding other special enforcement matters that could be the subject of future proposed regulations.

REG–104352–18, page 357. Proposed regulations implementing sections 245A(e) and 267A of the Internal Revenue Code regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities. This document also contains proposed regulations under: (1) sections 1503(d) and 7701 to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign country, and (2) sections 6038, 6038A, and 6038C to facilitate administration of these rules.

EMPLOYEE PLANS

NOTICE 2019–03, page 350. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for December 2018 used under § 417(e)(3)(D), the 24-month average segment rates applicable for December 2018, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

EMPLOYMENT TAX

NOTICE 2019–08, page 354. This Notice provides the maximum fair market value of a vehicle eligible to use the fleet-average and cents-per-mile special valuation rules of Treas. Reg. section 1.61–21(d) and (e), respectively, for 2018. These special valuation rules may be used to value an employee's personal use of an employer-provided vehicle for income and employment tax purposes.

INCOME TAX

NOTICE 2019–08, page 354. This Notice provides the maximum fair market value of a vehicle eligible to use the fleet-average and cents-per-mile special valuation rules of Treas. Reg. section 1.61–21(d) and (e), respectively, for 2018. These special valuation rules may be used to value an employee's personal use of an employer-provided vehicle for income and employment tax purposes.

Rev. Proc. 2019–08, page 347. This revenue procedure describes how taxpayers elect to expense under section 179(a) the cost of qualified real property and how taxpayers change their computation of depreciation for certain assets to the alternative depreciation system of section 168(g), for taxable years beginning after 2017. This revenue procedure also defines qualified real property under section 179. Effective date December 21, 2018, Rev. Proc. 87–57 and Rev. Proc. 2018–31 are modified.