ADMINISTRATIVE

NOTICE 2019–06, page 353. This notice informs taxpayers that the Department of the Treasury and the Internal Revenue Service intend to propose regulations addressing certain special enforcement matters under section 6241(11). Specifically, this Notice explains that proposed rules will be issued that provide the IRS may determine that the centralized partnership audit regime will not apply to adjustments to partnership-related items in certain limited circumstances and that partnerships with a qualified subchapter S subsidiary (QSub) are not eligible to elect out of the centralized partnership audit regime except by applying a rule similar to the rules for S corporations under section 6221(b)(2)(A) to the QSub partner. This notice also requests comments regarding other special enforcement matters that could be the subject of future proposed regulations.

REG–104352–18, page 357. Proposed regulations implementing sections 245A(e) and 267A of the Internal Revenue Code regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities. This document also contains proposed regulations under: (1) sections 1503(d) and 7701 to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign country, and (2) sections 6038, 6038A, and 6038C to facilitate administration of these rules.