Fc term lenders liquidating
The regulations address certain deficiencies and technical ambiguities in the existing section 707 regulations, including issues in determining a partner's share of liabilities under section 1.752–3 for disguised sale purposes.
Final and temporary regulations provide guidance concerning a partner's share of partnership liabilities for purposes of section 707 of the Code and the treatment of certain payment obligations under section 752. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for December 2016 used under § 417(e)(3)(D), the 24-month average segment rates applicable for December 2016, and the 30-year Treasury rates.
This notice contains the 2016 Required Amendments List for individually-designed qualified retirement plans.
This rev proc adds one country (Saint Lucia) to the list set forth in Section 3 and three countries (Israel, the Republic of Korea, and Saint Lucia) to the list set forth in Section 4.
The notice provides rules relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations.
In addition, the proposed regulations address (1) when certain obligations to restore a deficit balance in a partner's capital account are disregarded under section 704 and (2) when partnership liabilities are treated as recourse liabilities under section 752. This revenue ruling relates to allocations of low-income housing credits to qualified low-income buildings.
The proposed regulations provide rules under section 901(m) for determining the amount of foreign taxes that are disqualified for foreign tax credit purposes with respect to certain covered asset acquisitions that result in a basis step-up for U. Specifically, the revenue ruling clarifies that section 42(m)(1)(A)(ii) neither requires nor encourages State housing credit agencies to reject the proposed development of a low-income housing project that does not obtain the approval of the locality where the project is proposed to be developed.