INCOME TAX

T.D. 9630, page 199. These final regulations address concerns that taxpayers are taking unreasonable positions with respect to the determination of discount rates in applying the income method to determine taxable income in connection with cost sharing arrangements. The final regulations provide guidance on a discount rate-related specified application of the income method and a discount rate-related best method consideration for evaluating an application of the income method.

REG–113792–13, page 211. These proposed regulations provide guidance on the tax credit available to certain small employers that offer health insurance coverage to their employees under section 45R of the Code, enacted by the Patient Protection and Affordable Care Act. Comments requested by November 25, 2013.

Rev. Proc. 2013–33, page 209. This revenue procedure provides domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2011.