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.

EMPLOYEE PLANS

NOT 2019-40, page 59. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for June 2019 used under § 417(e)(3)(D), the 24-month average segment rates applicable for June 2019, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2) (C)(iv).

EXEMPT ORGANIZATIONS

ANN 2019-07, page 62. Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

INCOME TAX

T.D. 9863, page 1. The final regulations provide discounting rules for unpaid losses and estimated salvage recoverable of insurance companies for Federal income tax purposes. The final regulations update and replace existing regulations under section 846 of the Internal Revenue Code to implement recent legislative changes made by section 13523 of the Tax Cuts and Jobs Act.

T.D. 9864, page 6. The final regulations provide rules for governing the availability of charitable contribution deductions under section 170 when a taxpayer receives or expects to receive a corresponding state or local tax credit. Final regulations under section 642(c) apply similar rules to payments made by a trust or decedent's estate.

T.D. 9865, page 27. This document contains temporary regulations relating to the addition of section 245A to the Internal Revenue Code by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The temporary regulations affect United States persons that have undertaken certain transactions with regards to a controlled foreign corporation or own a controlled foreign corporation that has undertaken certain transactions.

NOT 2019-12, page 57. Notice 2019-12 announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to publish a proposed regulation providing a safe harbor under section 164 of the Internal Revenue Code for certain individuals who make a payment to or for the use of an entity described in section 170(c) in return for state or local tax credit.

REG-105476-18, page 63. Nonresident aliens and foreign corporations are taxable in the United States on taxable income which is effectively connected with the conduct of a trade or business within the United States. REG-113604-18 published on December 27, 2018, would provide rules for determining under section 864(c)(8) the amount of gain or loss recognized by a nonresident alien individual or foreign corporation from the sale or exchange of a partnership interest that is treated as effectively connected with the conduct of a trade or business within the United States. These proposed regulations would provide the withholding and reporting requirements related to these sales or exchanges.