INCOME TAX

REG–139483–13, page 475. The proposed regulations under section 367 primarily narrow the exception to section 367(a) for property transferred to a foreign corporation for use in the conduct of an active trade or business by limiting the exception to only certain classes of property, and eliminate the exception to section 367(d) for transfers of foreign goodwill or going concern value. The regulations also reorganize the regulations under section 367(a) and update cross-references where appropriate.

Rev. Rul. 2015–21, page 447. Federal rates; adjusted federal rates; adjusted federal longterm rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2015.

Rev. Proc. 2015–43, page 467. This revenue procedure supplements Rev. Proc. 2015–3, 2015–1 I.R.B. 129, which sets forth areas of the Internal Revenue Code (Code) on which the Internal Revenue Service will not issue letter rulings or determination letters (no-rule areas). The revenue procedure adds to the list of no-rule areas any issue relating to the qualification, under § 355 and related provisions of the Code, of certain distributions in which property becomes the property of a regulated investment company or a real estate investment trust, the active business is small relative to other assets, or there is a substantial amount of investment assets.

Rev. Proc. 2015–48, page 469. The Tax Increase Prevention Act of 2014 generally extends the application of § 168(k) 50% bonus depreciation, § 168(k)(4) “extension property,” and § 179(f) real property, for property placed in service in 2014. This revenue procedure provides guidance to taxpayers for making certain elections and filing amended returns to avail themselves of these extenders.

Finding Lists begin on page ii.