Overview
European Council Approves New System for Resolving Double Taxation Disputes Between Member States: In a directive released today, the European Council approved a new system for resolving double taxation disputes between member states. The directive strengthens the mechanisms used to resolve disputes that arise from the interpretation of agreements on the elimination of double taxation.
Miscellaneous Guidance:
Revenue Procedure 2017-56 updates Rev. Proc. 2000-40 to take into account the provisions of Internal Revenue Code Section 430, which was enacted as part of the Pension Protection Act of 2006. The revenue procedure provides automatic approval for certain changes in funding method used for single-employer defined benefit plans for calculations described under section 430.
Revenue Procedure 2017-57 updates Rev. Proc. 2000-41 to take into account the enactment of subsequent legislation and sets forth the procedure for obtaining IRS approval for a change in the funding method used for a defined benefit plan, as provided by section 412(d)(1) of the Internal Revenue Code and section 302(d)(1) of the Employee Retirement Income Security Act of 1974, as amended (ERISA). The revenue procedure also sets forth the procedure for obtaining IRS approval to revoke an election relating to interest rates pursuant to Internal Revenue Code section 430(h)(2)(D)(ii) or section 430(h)(2)(E) and the corresponding sections of ERISA.