INCOME TAX

REG-123112-19, page 1104. This document announces that the Department of the Treasury (Treasury Department) and the IRS intend to issue proposed regulations regarding the treatment of certain inter

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ests in corporations as stock or indebtedness and requests comments from the public regarding the contemplated rules. This document also announces that, following the expiration of the 2016 Temporary Regulations (described in the Background section of this advance notice of proposed rulemaking), a taxpayer may rely on the 2016 Proposed Regulations (also described in the Background) until further notice is given in the Federal Register, provided that the taxpayer consistently applies the rules in the 2016 Proposed Regulations in their entirety.

T.D. 9879, page 1052. TD 9879 provides guidance relating to information reporting obligations for reportable policy sales of life insurance contracts under §6050Y, which was added by section 13520 of the 2017 Tax Cuts and Jobs Act (the TCJA). TD 9879 also provides guidance under §101, as amended by section 13522 of the TCJA, for reportable policy sales and to make certain other related changes to the existing regulations under §101.

T.D. 9880, page 1085. This Treasury Decision removes final regulations identified by the Secretary of the Treasury as imposing an undue financial burden on taxpayers and as being unduly complex. The final regulations being removed set forth minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. This document also adopts conforming amendments to other final regulations to reflect the removal of those regulations.