Daily Tax Update - December 22, 2014: IRS and Treasury Release Proposed Regulations on Installment Obligations

IRS and Treasury Release Proposed Regulations on Installment Obligations:  Proposed regulations released today provide guidance on the realization of gain or loss on installment obligations under Section 453B.  The proposed regulations include the general rule, from regulations under former Section 453(d), that a transferor does not recognize gain or loss on dispositions of an installment obligation if gain or loss is not recognized on the disposition under another provision of the Internal Revenue Code.  The proposed regulations also incorporate guidance provided in Revenue Ruling 73-423 regarding disposal of an installment obligation that results in the satisfaction of the obligation.

Luxembourg Will Release Names of Taxpayers:  Luxembourg announced that it will provide the European Commission with the list of tax rulings issued by the tax administration and a list of the beneficiaries of its IP box regime.