January 17, 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. Revenue Ruling —01 sets forth the base period T-bill rate as determined by the Office of Debt Management within the Treasury Department for the period ending September 30, , and provides a table of factors compounded daily for taxpayers with short or alternative taxable years.
The eligibility rule, set out in section 5. Notice —08 Notice —08 The notice modifies Notice —66, —47 I. This revenue procedure also announces that because updated withholding foreign partnership WP and withholding foreign trust WT agreements will not be published before December 31, , WPs and WTs with agreements currently in effect may continue to treat those agreements as in effect until updated agreements are issued in January The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section of the Internal Revenue Code.
The regulations also combine certain sections of the existing regulations under section a into a single section. This document also withdraws certain temporary regulations. The final regulations amend the computation of the premium tax credit for families with children who enroll in health coverage through Exchanges offering qualified health plans that do not provide pediatric dental benefits, and address information reporting by Exchanges and other issues.
The final regulations are reserved on the effect of employer opt-out arrangements on the affordability of employer-provided health coverage for purposes of the premium tax credit and the section A individual shared responsibility provision. A professional employer organization, sometimes referred to as an employee leasing company, is an organization that enters into an agreement with a client to perform some or all of the federal employment tax withholding, reporting, and payment functions related to workers performing services for the client.
Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.
It is published weekly. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows: This part includes rulings and decisions based on provisions of the Internal Revenue Code of This part is divided into two subparts as follows: To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts.
This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The base period T-bill rate for the period ending September 30, , is 0. Pursuant to section of the Internal Revenue Code, interest must be compounded daily.
Generally, one would use the factor for days. For the base period T-bill rates for periods ending in prior years, see Rev. For further information regarding the revenue ruling, contact Mr. Nieters at not a toll-free number.