Bulletin No. 2013-13 March 25, 2013

REG–106918–08, page 714. Proposed regulations under sections 761 and 1234 of the Code relate to the tax treatment of noncompensatory options and convertible instruments issued by a partnership. Specifically, the proposed regulations expand the characterization rule measurement events to include certain transfers of interests in the issuing partnership and other look-through entities, and provide additional guidance in determining the character of the grantor’s gain or loss as a result of a closing transaction with respect to, or a lapse of, an option on a partnership interest. The proposed regulations will affect partnerships that issue noncompensatory options, the partnerships, and the holders of such options.

REG–148500–12, page 716. Proposed regulations relate to the shared responsibility payment for not maintaining minimum essential coverage under section 5000A of the Code, which was added by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, as amended by the TRICARE Affirmation Act and Public Law 111–173. A public hearing is scheduled for May 29, 2013.

Notice 2013–14, page 712. This notice provides guidance on section 309 of the American Taxpayer Relief Act of 2012, Pub. L. No. 112–240, enacted on January 2, 2013, which amends section 51 of the Code to extend the Work Opportunity Tax Credit through December 31, 2013. The notice also provides employers additional time beyond the 28-day deadline in section 51(d)(13) for submitting Form 8850, Pre-Screening Notice and Certification Request for the Work Opportunity Credit, to Designated Local Agencies.

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EMPLOYMENT TAX

Notice 2013–14, page 712. This notice provides guidance on section 309 of the American Taxpayer Relief Act of 2012, Pub. L. No. 112–240, enacted on January 2, 2013, which amends section 51 of the Code to extend the Work Opportunity Tax Credit through December 31, 2013. The notice also provides employers additional time beyond the 28-day deadline in section 51(d)(13) for submitting Form 8850, Pre-Screening Notice and Certification Request for the Work Opportunity Credit, to Designated Local Agencies.

March 25, 2013 2013–13 I.R.B.