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

REG-123652-18, page 1652. This notice of proposed rulemaking contains proposed regulations that implement the special enforcement pro-visions described in section 6241(11) of the centralized partnership audit regime enacted by the BBA in November 2015. The Tax Technical Corrections Act of 2018 (TTCA), which was enacted into law on March 23, 2018 as part of the Consolidated Appropriations Act, 2018, add-ed, among other things, section 6241(11) to the Code. Section 6241(11) provides authority for the Secretary to issue regulations that determine that the centralized partnership audit regime, or portions of it, do not apply to certain items if such items involve special enforcement matters. Section 6241(11) also authorizes the IRS to pre-scribe regulations adopting special rules related to such items. This notice of proposed rulemaking adds proposed §301.6241-7, provides rules regarding special enforcement matters under section 6241(11). In addition, this notice of proposed rulemaking includes some amendments to some of the final regulations under BBA to conform to the addition of the regulations implementing section 6241(11), to account the addition of section 6232(f) in the TTCA, to implement one of the items in Notice 2019-06, and to make some clarifying amendments to the previously finalized rules.

EMPLOYEE PLANS

NOTICE 2020-85, page 1645. This notice sets forth the updated mortality improvement rates and static mortality tables that are used for purposes of determining minimum funding requirements under § 430(h) (3) for 2022 and minimum present value under § 417(e)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2022 calendar year.

EXCISE TAX

NOTICE 2020-84, page 1645. Sections 4375 and 4376, added to the Code by the Afford-able Care Act, impose a fee on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans to help fund the Patient-Centered Outcomes Re-search Trust Fund (PCORTF). The fee originally expired on October 1, 2019, but was extended by the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019). This notice provides that the adjusted applicable dollar amount that applies for determining the PCORTF fee for policy years and plan years ending on or after October 1, 2020 and before October 1, 2021 is equal to $2.66. This adjusted applicable dollar amount has been determined using the percentage increase in the projected per capita amount of the National Health Expenditures published by HHS in March 2020.

INCOME TAX

T.D. 9926, page 1602. This document contains final regulations implementing certain sections of the Internal Revenue Code, including sections added to the Internal Revenue Code by the Tax Cuts and Jobs Act, that relate to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in the conduct of a trade or business within the United States. The final regulations affect certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in such conduct. TD 9926. Published November 30, 2020.