ADMNISTRATIVE

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.

Notice 2018–31, page 501. This notice impacts U.S. multinational enterprise groups that are required to file a Form 8975 and Schedule A (Form 8975) (Country-by-Country Report) (i.e., those that have more than $850M in revenue in the prior reporting period) and that have more than 50 percent of their revenues attributable to contracts with the Department of Defense or other U.S. governmental intelligence or security agencies. Such specified national security contractors may file their Country-by-Country Report in the modified manner described in the notice.

REG–132434–17, page 503. These proposed regulations will narrow the scope of the current summons interview regulations by excluding certain nongovernment attorneys from receiving summoned books, papers, records, or other data, or from participating in the interview of a witness summoned by the IRS to provide testimony under oath. An attorney who is not an officer or employee of the United States may not be hired by the IRS to perform these activities unless the attorney is hired by the IRS as a specialist in foreign, state, or local law, including tax law, or in non-tax substantive law that is relevant to an issue in the examination, such as patent law, property law, or environmental law, or is hired for knowledge, skills, or abilities other than providing legal services as an attorney.

Finding Lists begin on page ii.