INCOME TAX

REG–133673–15, page 697. While current law is clear that changes in conversion ratios in convertible instruments may result in deemed distributions under section 305, ambiguities exist whether the deemed distribution is of shares of stock or rights to acquire stock, and concerning the amount and timing of these deemed distributions. These proposed regulations clarify that the deemed distribution is of rights to acquire stock, and the amount and timing of the deemed distribution. Guidance is also provided to withholding agents regarding their withholding obligations under sections 860G, 861, 1441, 1461, 1471, and 1473, as well as information reporting guidance for such deemed distributions under section 6045B.

REG–135734–14, page 712. This document contains proposed regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The regulations are issued by cross-reference to temporary regulations in TD 9761.

Rev. Proc. 2016–24, page 677. This revenue procedure provides indexing adjustments for certain provisions under sections 36B and 5000A of the Internal Revenue Code. In particular, it updates the Applicable Percentage Table in § 36B(b)(3)(A)(i) to provide the Applicable Percentage Table for 2017 that is used to calculate an individual’s premium tax credit. This revenue procedure also updates the

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