ADMINISTRATIVE

Rev. Proc. 2017–12, page 424. The revenue procedure generally provides that the Internal Revenue Service will treat certain internal total loss-absorbing capacity (TLAC) instruments as indebtedness for federal tax purposes.

T.D. 9796, page 380. Final regulations treating a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Code.