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This Week's Internal Revenue Bulletin

NOV. 30, 2020

2020-49 IRB 1

DATED NOV. 30, 2020
DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-46677
  • Tax Analysts Electronic Citation
    2020 TNTG 230-36
    2020 TNTF 230-24
Citations: 2020-49 IRB 1

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

NOTICE 2020-81, page 1454. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2020 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2020, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

NOTICE 2020-82, page 1458. This notice provides that the IRS will treat a contribution to a single-employer defined benefit pension plan with an extended due date of January 1, 2021 pursuant to § 3608(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136, as timely if it is made no later than January 4, 2021 (which is the first business day after January 1, 2021).

T.D. 9929, page 1220. These final regulations respond to Executive Order 13877, “Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First” and are intended to increase consumer access to price information for health costs when third-party payers are involved. The final regulations set forth requirements for non-grandfathered group health plans and health insurance issuers of non-grandfathered coverage offering group health insurance coverage to disclose to a participant, beneficiary, or authorized representative for such individual, their cost-sharing liability for covered items or services from a particular provider. Under the final regulations, group health plans and health insurance issuers are required to make such information available for covered items and services through an internet website and through non-internet means. The final regulations also require plans and issuers to disclose provider negotiated rates and out-of-network provider allowed amounts through three machine-readable files posted on an internet website.

T.D. 9930, page 1400. This document sets forth final regulations providing guidance relating to the life expectancy and distribution period tables that are used to calculate required minimum distributions from qualified retirement plans, individual retirement accounts and annuities, and certain other tax-favored employer-provided retirement arrangements. These regulations affect participants, beneficiaries, and plan administrators of these qualified retirement plans and other tax-favored employer-provided retirement arrangements, as well as owners, beneficiaries, trustees and custodians of individual retirement accounts and annuities.

INCOME TAX

REG-101657-20, page 1466. 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 life insurance companies; the definition of a foreign income tax and a tax in lieu of an income tax; transition rules relating to the impact on loss accounts of net operating loss carrybacks allowed by reason of the Coronavirus Aid, Relief, and Economic Security Act; the definition of foreign branch category and financial services income; and the time at which foreign taxes accrue and can be claimed as a credit. This document also contains proposed regulations clarifying rules relating to foreign-derived intangible income

REV. PROC. 2020-48, page 1459. This revenue procedure prescribes discount factors for the 2020 accident year for insurance companies to compute discounted unpaid losses under § 846 of the Internal Revenue Code and discounted estimated salvage recoverable under § 832.

T.D. 9922, page 1139. This document contains final regulations that modify the foreign tax credit provisions following the Tax Cuts and Jobs Act. This document contains additional changes to the existing regulations regarding the allocation and apportionment of expenses. Additionally, this document contains guidance on the allocation and apportionment of foreign income taxes to categories of income for purposes of the foreign tax credit. This document also contains final regulations addressing hybrid deduction accounts, certain hybrid instruments, and certain payments under section 951A. Finally, this document also contains numerous other conforming changes to the existing foreign tax credit rules.

NOTICE 2020-75, page 1453. This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations to clarify that State and local income taxes imposed on and paid by a partnership or an S corporation on its income are allowed as a deduction by the partnership or S corporation in computing its non-separately stated taxable income or loss for the taxable year of payment.

DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-46677
  • Tax Analysts Electronic Citation
    2020 TNTG 230-36
    2020 TNTF 230-24
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