Code
Section | Abstract |
General real estate items |
61(a)(12) and 1001 | Guidance under Sections 61(a)(12) and 1001 on whether a recourse purchase money home mortgage loan is treated as a nonrecourse loan from inception if, under a state anti-deficiency statute, the lender cannot pursue the homeowner for the difference between the amount of the loan and the amount realized on a foreclosure or short sale of the home. |
| | Regulations relating to accruals of interest (including discount) on distressed debt. |
460 | Regulations under Section 460 addressing the application of the look-back interest rules to certain pass-through entities with tax-exempt owners. |
460 | Regulations under Section 460 regarding home construction contracts and rules for certain changes in method of accounting for long-term contracts. |
446 | Guidance under Sections 446, 1275 and 6050H to address the treatment and reporting of capitalized interest on modified home mortgages. |
1001 | Regulations under Section 1001 on the modification of debt instruments, including issues relating to disregarded entities. |
163(h)(3) | Guidance under Section 163(h)(3) concerning qualified residence interest. |
170 | Guidance under Section 170 regarding charitable contributions of appropriative water rights. |
170 | Guidance under Section 170 regarding charitable contributions of conservation easements. |
280A | Regulations under Section 280A regarding deductions for expenses attributable to the business use of homes and rental of vacation homes. |
168 and 179 | Guidance under Sections 168 and 179 necessitated by the Protecting Americans From Tax Hikes (PATH) Act of 2015. |
453A | Regulations under Section 453A regarding contingent payment sales. |
453B | Final regulations under Section 453B regarding nonrecognition of gain or loss on the disposition of certain installment obligations. Proposed regulations were published on December 23, 2014. |
167 | Guidance under Section 167 regarding a safe harbor for normalization. |
REIT items |
856 | Final regulations under Section 856 clarifying the definition of real property for purposes of the rules for REITs. Proposed regulations were published on May 14, 2014. |
856(c)(3) | Guidance clarifying the definition of income in Section 856(c)(3) for purposes of the REIT qualification tests. |
856(e)(6)(D)(ii) | Guidance defining congregate care for purposes of the definition of a REIT health care facility under Section 856(e)(6)(D)(ii) and (l)(4)(B). |
446 | Guidance under Section 446 relating to accounting for hedging transactions. |
Partnership items |
337 | Final regulations under Section 1.337(d)-3 relating to partnership transactions involving a corporate partner's stock or other equity interests. Final and temporary, and proposed regulations were published on June 12, 2015. |
469(h)(2) | Final regulations under Section 469(h)(2) concerning limited partners and material participation. Proposed regulations were published on November 28, 2011. |
514(c)(9) | Regulations concerning the fractions rule under Section 514(c)(9). |
704(b) | Guidance on targeted capital accounts under Section 704(b). |
704(c) | Regulations to update the securities partnership aggregation rules under Section 704(c). |
704, 707, 721 | Guidance under Sections 704, 707 and 721 on management fee waivers. Proposed regulations were published on July 22, 2015. |
704, 734, 743, and 755 | Final regulations under Sections 704, 734, 743 and 755 arising from the American Jobs Creation Act of 2004, regarding the disallowance of certain partnership loss transfers and no reduction of basis in stock held by a partnership in a corporate partner. Proposed regulations were published on January 16, 2014. |
707,752 | Regulations under Section 707 relating to disguised sales of property and regulations under Section 752 regarding a partner's share of liabilities. Proposed regulations were published on January 30, 2014. |
732(f) | Final regulations under Section 732(f) regarding aggregation of basis for partnership distributions involving equity interests of a partner. Proposed regulations were published on June 12, 2015. |
751(b) | Final regulations under Section 751(b) on unrealized receivables and inventory. Proposed regulations were published on November 3, 2014. |
752 | Final regulations under Section 752 on related-person rules. Proposed regulations were published on December 16, 2013. |
761 and 1234 | Final regulations under Sections 761 and 1234 on the tax treatment of noncompensatory partnership options. Proposed regulations were published on February 5, 2013. |
7704(d)(1)(E) | Final regulations under Section 7704(d)(1)(E) regarding qualifying income for publicly traded partnerships. Proposed regulations were published on May 6, 2015. |
7704(d)(1)(E) | Guidance under Section 7704(d)(1)(E) regarding qualifying income derived from fertilizer for publicly traded partnerships. |
Corporations and their shareholders |
355 | Guidance relating to the requirements under Section 355, including the active trade or business and business purpose requirements and the prohibition on device for the distribution of earnings and profits. (Issued July 15, 2016 in the Federal Register as REG-134016-15.) |
337(d) | Final regulations under Section 337(d) regarding certain transfers of C corporation property to real estate investment trusts and regulated investment companies. Temporary and proposed regulations were published on June 8, 2016. |
| | Guidance regarding when a transfer by a person to a corporation and a transfer by that corporation to that person, ostensibly in two separate transactions, should be respected as two separate transactions for federal income tax purposes. |
355 | Guidance regarding whether a corporation is a controlled corporation under Section 355 if, in anticipation of the distribution of its stock, the distributing corporation acquires or retains putative control of the controlled corporation through the use of classes of shares having different voting powers. (Published August 8, 2016 in IRB 2016-32 as Revenue Procedure 2016-40.) |
385 | Final regulations under Section 385 regarding treatment of certain interests in corporations as stock. Proposed regulations were published on April 8, 2016. |
General tax issues |
167, 1031 | Guidance under Sections 167 and 1031 regarding whether property held simultaneously for sale and for lease (also known as "dual-use property") is eligible for depreciation deductions and/or like-kind exchange treatment. |
1411 | Final regulations under Section 1411 regarding issues related to the net investment income tax. Proposed regulations were published on December 2, 2013. |
7701 | Final regulations under Section 7701 regarding Series LLCs and cell companies. Proposed regulations were published on September 14, 2010. |
1.267(b)-1(b) | Regulations under Section 267 regarding the application of Reg. Section 1.267(b)-1(b) to partners and partnerships. |
469 | Guidance regarding material participation by trusts and estates for purposes of Section 469. |
2704 | Guidance under Section 2704 regarding restrictions on the liquidation of an interest in certain corporations and partnerships. |
1446 | Regulations regarding publicly traded partnerships under Section 1446 and Treas. Reg. Section 1.1446-4. |
TEFRA | Guidance regarding partnership audit and adjustment procedures under TEFRA and the Bipartisan Budget Act of 2015. |
512 | Guidance under Section 512 regarding methods of allocating expenses relating to dual-use facilities. |
1411 | Final regulations under Section 1411 regarding issues related to the net investment income tax. Proposed regulations were published on December 2, 2013. |
International tax issues |
864 | Guidance under Section 864 implementing Revenue Ruling 91-32 relating to sales of certain partnership interests. |
892 | Regulations under Section 892. Proposed regulations were published on November 3, 2011. |
1446 | Regulations regarding publicly traded partnerships under Section 1446 and Treas. Reg. Section 1.1446-4. |
7701 | Regulations under Section 7701 coordinating the entity classification election with elections under subchapter M. |
7874, 367, 956, 7701(l), and 304 | Final regulations under Sections 7874, 367, 956, 7701(l) and 304 regarding inversions and related transactions. Temporary and proposed regulations were published on April 8, 2016. |
956 | Final regulations under Section 956 regarding the treatment of loans to foreign partnerships and related issues. Temporary and proposed regulations were published on September 2, 2015. |
864 | Guidance under Section 864 implementing Revenue Ruling 91-32 (which provides for look-through treatment for gain on certain partnership interest sales by a foreign person). |
721(c) | Guidance on transfers of property to partnerships with related foreign partners and controlled transactions involving partnerships. Notice 2015-54 was released on August 6, 2015. |
704(b) | Final regulations under Section 704(b) on the allocation by partnerships of foreign income tax. Temporary and proposed regulations were published on February 4, 2016. |
901 | Guidance under Section 901, including on the allocation of foreign tax imposed on disregarded entities and partnerships. |
954(c) | Guidance under Section 954(c), including regarding foreign currency gains, and the active rents and royalties exception. Temporary and proposed regulations were published on September 2, 2015. |
956 | Final regulations on the treatment of upfront payments on swaps under Section 956. Temporary and proposed regulations were published on May 8, 2015. |
959 | Final regulations under Section 959 on previously taxed earnings and profits. Proposed regulations were published on August 29, 2006. |
871(m) | Final regulations under Section 871(m) on dividend equivalent payments. Final, temporary, and proposed regulations were published on September 18, 2015. |
897 and 1445 | Regulations under Sections 897 and 1445 relating to changes in the PATH Act of 2015. |
482 | Guidance under Section 482, including with respect to the treatment and allocation of risk. Temporary and proposed regulations were published on September 16, 2015. |
Executive compensation, health care and other benefits, and employment taxes |
83(b) | Final regulations regarding election procedures under Section 83(b). Proposed regulations were published on July 17, 2015. |
162(m) | Guidance under Section 162(m) addressing certain situations involving a short tax year. |
Tax-exempt bonds |
103 | Regulations on the definition of political subdivision under Section 103 for purposes of the tax-exempt, tax credit, and direct-pay bond provisions. Proposed regulations were published on February 23, 2016. |
Credits and Incentives |
45D | Final regulations under Section 45D that revise and clarify certain rules relating to recapture of the new markets tax credit as well as other issues. Proposed regulations were published August 11, 2008. |
48 | Guidance on the definition of qualifying energy property under Section 48. |
48 | Guidance on the modification, extension and phase out of the investment tax credit for solar energy property under Section 48. |
50(d)(5) | Guidance concerning the interaction of the rules in Section 50(d)(5) and subchapter K. |
42 | Guidance concerning renewable energy and maximum gross rent under Section 42. Regulations under Section 42 on compliance monitoring, including issues identified in Notice 2012-18. Proposed and temporary regulations were published on February 25, 2016. |
