INCOME TAX

T.D. 9632, page 241. Final regulations on the requirement to maintain minimum essential coverage under §5000A, which was enacted 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. These final regulations provide guidance to individual taxpayers on the liability under §5000A for the shared responsibility payment for not maintaining minimum essential coverage and largely finalize the rules in the notice of proposed rulemaking (REG–148500–12) published in the Federal Register (78 FR 7314) on February 1, 2013.

T.D. 9633, page 227. These final regulations prevent the duplication of a net loss when loss assets are contributed to a corporation in a section 351 nonrecognition exchange. Under the regulations, the duplication of a net loss is prevented by reducing the transferee-corporation’s basis in the assets transferred, unless the transferor-shareholder elects to reduce its basis in the stock received in the exchange by the amount that would otherwise have been applied to reduce the corporation’s basis in its assets. Notice 2005–70 is obsolete.