INCOME TAX

Action On Decision 2016–03, page 424. Nonacquiescence to the holding that all events fixing a liability for federal income tax purposes occur when discount fuel purchase coupons are issued to a customer for retail grocery purchases.

Notice 2016–52, page 425. Notice 2016–52 provides guidance relating to certain transactions, undertaken in anticipation of foreign-initiated adjustments to foreign income tax liabilities of section 902 corporations, which will be treated as splitter arrangements under section 909.

Notice 2016–55, page 432. This notice provides that the IRS will not assert that cash payments an employer makes to §170(c) organizations (in exchange for vacation, sick, or personal leave that its employees elect to forgo) constitute gross income or wages of the employees under certain circumstances.