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

T.D. 9881, page 1288. This document contains final regulations amending the Health Insurance Providers Fee regulations to require certain covered entities engaged in the business of providing health insurance for United States health risks to electronically file Form 8963, “Report of Health Insurance Provider Information.”

Rev. Proc. 2019-42, page 1298. This revenue procedure will update Rev. Proc. 2019-09, 2019-02 I.R.B. 292, and identifies circumstances under which the disclosure on a taxpayer's income tax return with respect to an item or position is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code (relating to the substantial understatement aspect of the accuracy-related penalty), and for the purpose of avoiding the tax return preparer penalty under section 6694(a) (relating to understatements due to unreasonable positions) with respect to income tax returns. This revenue procedure will apply to any income tax return filed on 2019 tax forms for a taxable year beginning in 2019, and to any income tax return filed in 2020 on 2019 tax forms for short taxable years beginning in 2020.

Rev. Proc. 2019-46, page 1301. This procedure provides the rules for substantiating the deductible expenses of using an automobile for business, moving, medical, or charitable purposes. The revenue procedure also provides rules for substantiating the amount of an employee's ordinary and necessary business expenses of local travel or transportation away from home that a payor (an employer, its agent, or a third party) reimburses using a mileage allowance. Rev. Proc. 2010-51 is modified.

EMPLOYEE PLANS

Notice 2019-60, page 1292. Notice 2019-60 provides temporary relief with respect to the nondiscrimination requirements relating to benefits, rights, and features under closed defined benefit plans that generally meet the eligibility conditions for the relief provided in Notice 2014-5, 2014-2 I.R.B. 276, as extended.

Notice 2019-61, page 1294. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2019 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2019, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

INCOME TAX

Rev. Rul. 2019-26, page 1286. Federal rates; adjusted federal rates; adjusted federal long-term rate, the long-term exempt rate, and the blended annual rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for December 2019.

T.D. 9883, page 1289. These regulations provide rules regarding attribution for purposes of determining whether a person is a related person with respect to a controlled foreign corporation. They also provide rules for determining whether rents are derived in the active conduct of a trade or business for purposes of computing foreign personal holding company income. The regulations affect United States persons with direct or indirect ownership interests in certain foreign corporations.