Bulletin No. 2016–48 November 28, 2016

Notice 2016–68, page 774. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2016 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2016, and the 30-year Treasury rates. These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112-141 (MAP21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA).

T.D. 9792, page 751. This document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income (FPHCI), as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions. The final regulations affect United States shareholders of CFCs.

T.D. 9793, page 768. This document contains final regulations that remove the 36month non-payment testing rule from the list of identifiable events that cause a deemed discharge that must be reported to the IRS on a Form 1099–C.