Bulletin No. 2016–52 December 27, 2016

well as a list of countries with which the Treasury Department and the IRS have determined that it is appropriate to have an automatic exchange relationship with respect to that interest income information under §§1.6049–8(a) and 1.6049–4(b)(5) (Section 4). This rev proc adds one country (Saint Lucia) to the list set forth in Section 3 and three countries (Israel, the Republic of Korea, and Saint Lucia) to the list set forth in Section 4.

Notice 2016–73, page 908. The notice provides rules relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations. In addition, the notice announces that the Treasury and IRS will revise the regulations under section 367 in the manner described in the notice, and states our view that the IRS intends to challenge the purported tax consequences of these transactions under current law.

Notice 2016–77, page 914. This notice relates to a preference needed in a qualified allocation plan (QAP) for certain areas. Specifically, the notice reminds taxpayers that a project located in a qualified census tract (as defined in section 42(d)(5)) is not described in section 42(m)(1)(B)(ii)(III) (i.e., was not given a preference required in a QAP) unless the development of the project contributes to a concerted community revitalization plan.

Notice 2016–79, page 918. This notice provides the optional 2017 standard mileage rates for taxpayers to use in computing the deductible costs of operating an automobile for business, charitable, medical, or moving expense purposes. This notice also provides the amount taxpayers must use in calculating reductions to basis for depreciation taken under the business standard mileage rate, and the maximum standard automobile cost that may be used in computing the allowance under a fixed and variable rate (FAVR) plan.

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T.D. 9787, page 878. Final regulations under section 707 of the Code relate to disguised sales of property to or by a partnership. The regulations address certain deficiencies and technical ambiguities in the existing section 707 regulations, including issues in determining a partner’s share of liabilities under section 1.752–3 for disguised sale purposes.

T.D. 9788, page 889. Final and temporary regulations provide guidance concerning a partner’s share of partnership liabilities for purposes of section 707 of the Code and the treatment of certain payment obligations under section 752.

T.D. 9800, page 899. The temporary regulations provide rules under section 901(m) for determining the amount of foreign taxes that are disqualified for foreign tax credit purposes with respect to certain covered asset acquisitions that result in a basis step up for U.S. income tax purposes but not foreign tax purposes.