HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

T.D. 9637, page 427 These final regulations remove any reference to, or requirement of reliance on, credit ratings in regulations under the Internal Revenue Code and provide substitute standards of creditworthiness where appropriate, pursuant to the Dodd-Frank Act.

REG–124148–05, page 444 Research expenditures under Section 174. Theses proposed regulations provide guidance on the treatment of amounts paid or incurred in connection with the development of tangible property, including pilot models. Comments requested by December 5, 2013. A public hearing is scheduled for January 8, 2014.

REG–161948–05, page 449 These proposed regulations apply when a corporation that is subject to U.S. income tax acquires loss property tax-free from a liquidating subsidiary, from shareholders or others in a capital contribution, or from another corporation or person in a reorganization, and the loss in the acquired property accrued outside the U.S. tax system. The proposed regulations provide guidance for preventing the importation of loss in such cases by requiring the bases of the assets received to be equal to value.

Notice 2013–60, page 431 Clarification of Notice 2013–29. Notice 2013–29 provided two methods to determine when construction has begun on a qualified energy facility. This notice clarifies Notice 2013–29 regarding (i) the determination of whether a taxpayer satisfies either of those methods with respect to a facility, (ii) the applicability of the “master contract” provision in that notice, and (iii) the effect of a transfer of a facility after construction has begun.

Finding Lists begin on page ii. Index for July through October begins on page iv.