SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue regulations providing clarification of the effect of newly enacted section 67(g) of the Internal Revenue Code (Code) on the deductibility of certain expenses described in section 67(b) and (e) and § 1.67–4 of the Income Tax Regulations that are incurred by estates and non-grantor trusts. Section 67(g) was added 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 (Act), which was enacted December 22, 2017. This notice also requests comments on issues relating to section 642(h)(2) and § 1.642(h)–2(a) in light of new section 67(g).