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

Rev. Rul. 2013–25, page 802. Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning January 1, 2014, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for the underpayments, and 5 percent for large corporation underpayments. The rate of interest paid on the portion of a corporation overpayment exceeding $10,000 will be 0.5 percent.

T.D. 9648, page 798. These final regulations provide a definition of the term �specified notional principal contract� with respect to a payment of a dividend equivalent made prior to January 1, 2016. These final regulations also amend other provisions of the Code to address the treatment of dividend equivalents, such as withholding rules.

REG–120282–10, page 837. These proposed regulations describe payments that are dividend equivalents for purposes of section 871(m) and explain how to calculate the amount of a dividend equivalent. These proposed regulations also provide guidance regarding when payments will constitute dividend equivalents and U.S. source income. Comments are requested by March 5, 2014. A public hearing is scheduled for April 11, 2014.

REG–126285–12, page 853. These proposed regulations concern the deductibility of start-up expenditures and organizational expenses for partnerships. The proposed regulations provide guidance regarding the deductibility of start-up expenditures and organizational expenses for partnerships following a technical termination of a partnership. Comments are requested by March 10, 2014.

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