INCOME TAX

Notice 2018–26, page 480. This notice provides additional guidance regarding the implementation of section 965 of the Internal Revenue Code as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018”, P.L. 115–97, which was enacted on December 22, 2017.

Notice 2018–28, page 492. This notice announces that the Department of the Treasury and the Internal Revenue Service (IRS) intend to issue proposed regulations providing guidance to assist taxpayers in complying with section 163(j) of the Internal Revenue Code (Code), as amended on December 22, 2017, by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115–97 (the Act). This notice further describes certain of the rules that those proposed regulations will include to provide taxpayers with interim guidance as more comprehensive guidance is developed. The rules described in this notice apply only for purposes of determining the limitation on deductions for interest expense under section 163(j), as amended by the Act.

Notice 2018–29, page 495. This notice announces that the Treasury Department and the IRS intend to issue regulations under new section 1446(f)

regarding the disposition of a partnership interest that is not publicly traded. This notice also provides interim guidance that taxpayers may rely on pending the issuance of regulations.

Rev. Rul. 2018–10, page 477. Fringe benefits aircraft valuation formula. For purposes of section 1.61–21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employerprovided aircraft, the Standard Industry Fare Level (SIFL) centsper-mile rates and terminal charge in effect for the first half of 2018 are set forth.

T.D. 9832, page 477. These final regulations provide rules addressing the allocation of the credit for increasing research activities to corporations and trades or businesses under common control. These final regulations also contain rules relating to the allocation of the railroad track maintenance credit and the election for a reduced research credit.