Daily Tax Update - June 10, 2015: Treasury, IRS Issue Proposed Regulations Regarding Consolidated Returns

Treasury, IRS Issue Proposed Regulations Regarding Consolidated Returns:  Today, Treasury and the IRS issued proposed regulations (REG-101652-10) to (1) provide guidance regarding the absorption of consolidated group members’ losses in a consolidated return year; (2) eliminate the “circular basis problem” in a broader class of transactions than under current law; and (3) amend Treas. Reg. § 301.6402-7(g) by revising the definition of separate net operating loss of a member in light of proposed amendments to Treas. Reg. § 1.1502-21. 

Vatican, United States Sign Agreement to Combat Tax Evasion:  Today, the Holy See and the United States signed an agreement under the U.S. Foreign Account Tax Compliance Act (FATCA).  According to a statement released by the Vatican, the agreement, which is the first formal inter-governmental agreement between the Holy See and the United States, “will prevent tax evasion and facilitate the compliance of fiscal duties by those U.S. citizens who conduct financial activities in Vatican City State.” 

Miscellaneous Guidance:
Notice 2015-42 provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates under section 417(e)(3) and the 24-month-average segment rates under section 430(h)(2).