Daily Tax Update - January 13, 2017: IRS Releases Inversions Regulations Package

IRS Releases Inversions Regulations Package:  Today the Treasury Department and the IRS released final and temporary regulations (T.D. 9812) under section 7874 focusing on inversion transactions.  The final regulations adopt, with certain amendments, prior temporary regulations issued in 2014 and 2016.  Specifically, the regulations identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation.  In addition, the final regulations provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership.  

House Passes Budget Resolution, Takes Step Toward Repealing ACA:  Today the House passed S. Con. Res. 3 by a vote of 227-198, paving the way for the dismantling of the Affordable Care Act (ACA).  The Senate passed the budget resolution late early Thursday morning by a vote of 51-48.  

Miscellaneous Guidance: 
Revenue Procedure 2017-18 provides that the last day of the remedial amendment period for section 403(b) plans, for purposes of section 21 of Revenue Procedure 2013-22, is March 31, 2020.

Notice 2017-13 provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under section 417(e)(3), and the 24-month average segment rates under section 430(h)(2).  In addition, the notice provides guidance as to the interest rate on 30-year Treasury securities under section 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under section 431(c)(6)(E)(ii)(I).