Overview
IRS Issues Final Regulations on Reporting for Foreign-Owned US Entities: Today, the IRS and Treasury issued final regulations that treat a domestic disregarded entity that is wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance, and associated compliance requirements that apply to 25% foreign-owned domestic corporations under section 6038A. The final regulations adopt with some changes proposed regulations issued in May. They are effective as of December 13.
IRS Issues Guidance on Low-Income Housing Tax Credit: Today, the IRS released two pieces of guidance relating to the low-income housing tax credit under section 42. Notice 2016-77 serves as a reminder to taxpayers that a project is not described in section 42(m)(1)(B)(ii)(III) unless its development contributes to a concerted community revitalization. Revenue Ruling 2016-29 clarifies that when state housing credit agencies allocate housing dollar amounts, section 42(m)(1)(A)(ii) does not require or encourage these agencies to reject all proposals that do not obtain the approval of the locality where the project developer proposes to place the project.