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Notice 2010-29 is proposed to be ob­

Internal Revenue Bulletin 2020-17 · 2026-10-03 edition · updated 2026-10-04 · United States

soleted for taxable years beginning after December 31, 2017.

Special Analyses

This regulation is not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memorandum of Agreement (April 11, 2018) between the Treasury Department and the Office of Management and Budget regarding re­ view of tax regulations.

Paperwork Reduction Act

The collection of information relating to this notice of proposed rulemaking will be submitted to the Office of Management and Budget for review under OMB Con­ trol Number 1545-0123 in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)). In response to the Conference Report, §1.6012-2 of the proposed regulations would require an insurance company to include the insurance company’s annual statement (as defined in §1.6012-2(c)(5)) with an electronically filed Federal in­ come tax return (Form 1120-L for a life insurance company and Form 1120-PC for a nonlife insurance company). Federal income tax items of an insurance compa­ ny are determined in part based upon the insurance company’s annual statement. Providing the annual statement to the IRS with an electronically filed Federal in­ come tax return is necessary to allow the IRS to better and more efficiently examine an insurance company’s Federal income tax return.

In accordance with section 807(e) (6), as added by the TCJA, §1.807-3 of the proposed regulations provides that the IRS may require reporting on Form 1120-L of the opening balance and clos­ ing balance of items described in sec­

tion 807(c) (for example, life insurance reserves) and the method of computing such items for purposes of determining income. Providing this information is necessary to allow the IRS to better ex­ amine an insurance company’s Federal income tax return.

For purposes of the Paperwork Reduc­ tion Act, the burden for the collection of information associated with §1.6012-2 of the proposed regulations will be reflected in the burden on the Form 1120-L and in the burden on the Form 1120-PC (OMB Control Number 1545-0123) when the burden for each is revised to reflect the collection of information associated with §1.6012-2 of the proposed regulations. The respondents to the collection of infor­ mation are life insurance companies that file the Form 1120-L electronically and nonlife insurance companies that file the Form 1120-PC electronically.

For purposes of the Paperwork Reduc­ tion Act, the burden for the collection of information associated with §1.807-3 of the proposed regulations will be reflected in the burden on the Form 1120-L (OMB Control Number 1545-0123) when the burden is revised to reflect the collection of information associated with §1.807-3 of the proposed regulations. The respon­ dents to the collection of information are life insurance companies that file a Form 1120-L. Comments on the collection of infor­ mation should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of the Trea­ sury, Office of Information and Regula­ tory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, SE:­ CAR:MP:T:T:SP, Washington, DC 20224. Comments on the collection of informa­ tion should be received by June 1, 2020. Comments are specifically requested con­ cerning:

Whether the proposed collection of in­ formation is necessary for the proper per­ formance of the functions of the IRS, in­ cluding whether the information will have practical utility;

How the quality, utility, and clarity of the information to be collected may be en­ hanced;

How the burden of complying with the proposed collection of information

may be minimized, including through the application of automated collection tech­ niques or other forms of information tech­ nology; and

Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide informa­ tion.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it dis­ plays a valid control number assigned by the Office of Management and Budget.

Regulatory Flexibility Act

It is hereby certified that the proposed regulations will not have a significant eco­ nomic impact on a substantial number of small entities pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6).

Section 13517 of the TCJA added sec­ tion 807(e)(6) to the Code. Under section 807(e)(6), the Secretary may require re­ porting (at such time and in such manner as the Secretary shall prescribe) with re­ spect to the opening balances and the clos­ ing balances of reserves and with respect to the method of computing reserves for purposes of determining income. Section 1.807-3 of the proposed regulations would allow the IRS to require the reporting of this information on any prescribed forms, such as the Form 1120-L.

The Conference Report at 478-479 provides that, under existing authority, the Secretary may require an insurance company to provide its annual statement via a link, electronic copy, or other sim­ ilar means. Section 1.6012-2(c) of the proposed regulations would require an insurance company to include the insur­ ance company’s annual statement with an electronically filed Federal income tax return (Form 1120-L for a life insurance company and Form 1120-PC for a non­ life insurance company). Under current procedures, an insurance company can only electronically file a Form 1120-L or Form 1120-PC if the insurance compa­ ny is part of an affiliated group filing a consolidated return, the parent of which files a Form 1120. Although data are not readily available, the IRS and the Trea­ sury Department expect that any report­ ing burden associated with §1.6012-2(c) of the proposed regulations will fall pri­

April 20, 2020 676 Bulletin No. 2020–17

marily on financial and insurance firms with annual receipts greater than $41.5 million and, therefore, will not affect a substantial number of small entities. See 13 CFR 121.201, sector 52 (finance and insurance).

As stated in the preceding paragraph, the rule is not expected to affect a substan­ tial number of small entities; however, even if a substantial number of small en­ tities were affected, the economic impact of the regulation is not likely to be sig­ nificant. Section 1.807-3 of the proposed regulations is limited in scope to time and manner of information reporting, and any economic impact associated with this pro­ posed regulation is expected to be mini­ mal. Further, the information reported to the IRS is information that the insurance company has readily available.

Notwithstanding this certification, the Treasury Department and the IRS invite comments on the impact this rule would have on small entities.

Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Adminis­ tration for comment on its impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS as prescribed in this preamble under the ADDRESSES heading. The Treasury Department and the IRS request comments on all aspects of the proposed rules and the other pro­ posed actions described herein. All com­ ments that are submitted by the public will be available for public inspection and copying at http://www.regulations.gov or upon request.

A public hearing will be scheduled if requested in writing by any person that timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in the Federal Register .

Drafting Information

The principal author of these regula­ tions is Dan Phillips, Office of Associate

Chief Counsel (Financial Institutions and Products), IRS. However, other personnel from the Treasury Department and the IRS participated in their development.

Statement of Availability of IRS Documents

The IRS notices, revenue procedures, and revenue rulings cited in this pream­ ble are published in the Internal Revenue Bulletin (or Cumulative Bulletin) and are available from the Superintendent of Doc­ uments, U.S. Government Publishing Of­ fice, Washington, DC 20402, or by visit­ ing the IRS website at http://www.irs.gov .

List of Subjects

26 CFR Part 1

Income taxes, Reporting and record­ keeping requirements.

26 CFR Part 301

Employment taxes, Estate taxes, Ex­ cise Taxes, Gift taxes, Income taxes, Penalties, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

Accordingly, 26 CFR parts 1 and 301 are proposed to be amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 is amended by adding a sectional authority for §1.807-3 in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * *


Section 1.807-3 also issued under 26 U.S.C. 807(e)(6).


§1.338-11 [Amended]

Par. 2. Section 1.338-11 is amended by:

  1. Revising paragraph (d)(2).

  2. Removing the language “and (d)(3) (iii)” from the first sentence in paragraph (d)(3)(i) and adding “through (iv)” in its place.

  3. Redesignating paragraph (d)(3)(iii) as paragraph (d)(3)(iv).

  4. Adding a new paragraph (d)(3)(iii).

  5. Revising newly redesignated para­ graph (d)(3)(iv).

  6. Adding paragraph (d)(7)(iii). The revisions and additions read as fol­ lows:

§1.338-11 Effect of section 338 election on insurance company targets.


(d) * * * (2) Exception . New target is not treat­ ed as receiving additional premium under paragraph (d)(1) of this section if it is un­ der state receivership as of the close of the taxable year for which the increase in re­ serves occurs.

(3) * * * * * (iii) Increases in section 807(c) re- serves . The positive amounts with respect to the items referred to in section 807(c) other than discounted unpaid loss reserves is the sum of the net increases in such items that are required to be taken into ac­ count under section 807(f).

(iv) Increases in other reserves. The positive amount with respect to reserves other than discounted unpaid loss re­ serves and other items referred to in sec­ tion 807(c) is the net increase of those reserves due to changes in estimate, methodology, or other assumptions used to compute the reserves (including the adoption by new target of a methodology or assumptions different from those used by old target).


(7) * * * (iii) Application of paragraphs (d)(2) and (3) of this section . Paragraphs (d) (2) and (3) of this section apply to tax­ able years beginning on or after [DATE FINAL REGULATIONS ARE PUB- LISHED IN THE FEDERAL REGIS- TER] . For taxable years beginning before such date, see paragraph (d) of this section as contained in 26 CFR part 1 revised as of April 1, 2019.


§1.381(c)(22)-1 [Amended]

Par. 3. In §1.381(c)(22)-1, paragraph (b)(6) is removed and reserved.

Bulletin No. 2020–17 677 April 20, 2020

§1.801-2 [Amended]

of the Commissioner of Internal Revenue or his delegate (Commissioner) pursuant to administrative procedures prescribed by the Commissioner. Similarly, an insur­ ance company other than a life insurance company (a nonlife insurance company) that changes its basis of computing life in­ surance reserves must obtain the consent of the Commissioner pursuant to adminis­ trative procedures prescribed by the Com­ missioner.

(b) Section 481 adjustment —(1) In general . If the basis of computing any item referred to in section 807(c) as of the close of any taxable year (the year of change) differs from the basis of comput­ ing such item at the close of the preceding taxable year, then the difference between the amount of the item at the close of the taxable year computed on the new basis and the amount of the item at the close of the taxable year computed on the old basis that is attributable to contracts issued be­ fore the taxable year, is taken into account under section 481 and §§1.481-1 through 1.481-5 as an adjustment attributable to a change in method of accounting.

(2) Loss of company status . If for any taxable year a taxpayer that was an in­ surance company for the year of change is no longer an insurance company, then the taxpayer must take into account in the preceding taxable year (that is, the last taxable year it was an insurance compa­ ny) the balance of any section 481(a) ad­ justment determined under paragraph (b) (1) of this section. A taxpayer that was an insurance company for the year of change does not accelerate the balance of any sec­ tion 481(a) adjustment determined under paragraph (b)(1) of this section merely because it changes from a life insurance company to a nonlife insurance company or because it changes from a nonlife in­ surance company to a life insurance com­ pany.

(c) Effect on determining increase or decrease in reserves —(1) Effect under section 807(a) and (b) . If there is a change in basis of computing any item described in section 807(c) for a taxable year, then, for purposes of section 807(a) and (b), the closing balance for such item for the year of change with respect to contracts issued before the year of change is determined on the old basis and the opening balance for such item for the next taxable year for

Par. 4. Section 1.801-2 is amended by removing the language “1.801-7” and adding the language “1.801-6” in its place.

Par. 5. Section 1.801-5 is amended by:

  1. Removing paragraph (c) and redes­ ignating paragraph (d) as paragraph (c).

  2. In newly redesignated paragraph (c), designating the Example as paragraph (c) (1).

  3. In newly designated paragraph (c) (1):

i. Designating the introductory text as paragraph (c)(1)(i).

ii. Adding a heading for the table in newly designated paragraph (c)(1)(i).

iii. Designating the undesignated para­ graph following newly designated para­ graph (c)(1)(i) as paragraph (c)(1)(ii).

  1. Adding reserved paragraph (c)(2). The addition reads as follows:

§1.801-5 [Amended]


(c) * * * (1) * * * (i) * * * Table 1 to Paragraph (c)(1)(i)


§1.801-7 [Removed and Reserved]

Par. 6. Section 1.801-7 is removed and reserved.

§1.801-8(e) [Amended]

Par. 7. In §1.801-8, paragraph (e) is re­ moved and reserved.

§1.806-4 [Removed]

Par. 8. Section 1.806-4 is removed. Par. 9. Section 1.807-1 is revised to read as follows:

§1.807-1 Computation of life insurance reserves .

(a) No asset adequacy reserve . The life insurance reserve determined under section 807(d)(1) does not include any asset ade­ quacy reserve. An asset adequacy reserve includes any reserve that is established as an additional reserve based upon an analy­

sis of the adequacy of reserves that would otherwise be established or any reserve that is not held with respect to a particular contract. In determining whether a reserve is a life insurance reserve, the label placed on such reserve is not determinative, pro­ vided, however, any reserve or portion of a reserve that would have been established pursuant to an asset adequacy analysis re­ quired by the National Association of In­ surance Commissioner’s Valuation Manual 30 as it existed on December 22, 2017, the date of enactment of Public Law 115-97, is an asset adequacy reserve.

(b) Applicability date . The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER] .

Par. 10. Section 1.807-3 is added to read as follows:

§1.807-3 Reporting of reserves .

(a) Reserve reporting . A life insurance company subject to tax under section 801 is required to make a return on Form 1120L, U.S. Life Insurance Company Income Tax Return . The Internal Revenue Service may require reporting with respect to the opening balance and closing balance of items described in section 807(c) and with respect to the method of computing such items for purposes of determining income. Such reporting may provide for the man­ ner in which separate account items are re­ ported. (See section 6011 and §301.60111 of this chapter.) (b) Applicability date . The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER] .

Par. 11. Section 1.807-4 is added to read as follows:

§1.807-4 Adjustment for change in computing reserves .

(a) Requirement to follow administra- tive procedures . Except as provided in §1.446-1(e), a change in basis of comput­ ing an item referred to in section 807(c) is a change in method of accounting for purposes of §1.446-1(e). Before comput­ ing such item under a new basis, a life in­ surance company must obtain the consent

April 20, 2020 678 Bulletin No. 2020–17

such contracts is computed on the new ba­ sis.

(2) Effect under section 832 . The fol­ lowing rules apply for purposes of section 832(b)(4): (i) For the year of change, life insur­ ance reserves at the end of the year of change with respect to contracts issued before the year of change are determined on the old basis.

(ii) For the taxable year following the year of change, life insurance reserves at the end of the preceding taxable year (that is, the year of change) with respect to con­ tracts issued before the year of change are determined on the new basis.

(d) Examples . The principles of para­ graphs (a) through (c) of this section are illustrated by the following examples. For purposes of these examples and ex­ cept as otherwise provided, IC is a life insurance company within the meaning of section 816(a) that issues life insur­ ance and annuity contracts. IC is required to determine the amount of life insurance reserves under section 807(d) and to take net increases or decreases in the reserves into account in computing life insurance company taxable income. IC’s reserve for each insurance contract at issue exceeds the net surrender value for such contract and does not exceed the statutory reserve for such contract. IC uses a calendar year as its taxable year.

(1) Example 1 —(i) Facts . In 2021, IC discovered that it had computed the amount of life insurance re­ serves for its 2019 and 2020 taxable years by using a mortality table that was not permitted by the tax reserve method (as defined in section 807(d)(3)).

(ii) Analysis . To comply with section 807(d), IC must use the appropriate mortality table to compute its life insurance reserves for the 2021 taxable year. This change is a change in basis of computing life insurance reserves and a change in method of ac­ counting described in §1.446-1(e). IC is required to obtain the consent of the Commissioner to change its basis of computing its life insurance reserves by following the administrative procedures prescribed by the Commissioner.

(2) Example 2 —(i) Facts . IC issues variable an­ nuity contracts with guaranteed minimum benefits. In Year 1, the National Association of Insurance Commissioners makes a change to the Commission­ ers’ Annuity Reserve Valuation Method that impos­ es a new computational requirement on issuers of variable annuities with guaranteed minimum ben­ efits. The requirement applies to the determination of statutory reserves as of December 31, Year 1, for contracts issued on or prior to December 31, Year 1.

(ii) Analysis . To comply with section 807(d), IC must compute its life insurance reserves for variable annuities with guaranteed minimum benefits for the

Year 1 taxable year using the new computational requirement. This change is a change in basis of computing life insurance reserves for such contracts issued prior to Year 1 and a change in method of ac­ counting described in §1.446-1(e). IC is required to obtain the consent of the Commissioner to change its basis of computing its life insurance reserves by following the administrative procedures prescribed by the Commissioner.

(3) Example 3 —(i) Facts . In 2021, IC changed the basis of computing the amount of life insurance reserves for a certain type of life insurance contract as described in section 807(f). Both the basis used for computing the reserves for the relevant contracts at the close of the 2020 taxable year (old basis) and the basis of computing the reserves for the relevant type of contract at the close of the 2021 taxable year (new basis) are consistent with the applicable Com­ missioners’ Reserve Valuation Method. IC followed the administrative procedures prescribed by the Commissioner to obtain consent to change the basis of computing these reserves. IC determined that the life insurance reserves as of December 31, 2021, for the relevant contracts issued prior to 2021 were $110 if computed using the old method and $120 if com­ puted using the new method. IC also determined that the life insurance reserves as of December 31, 2021, for the relevant contracts issued during 2021 were $15 using the new basis.

(ii) Analysis . IC must take into account under section 481 and the administrative procedures pre­ scribed by the Commissioner the $10 difference be­ tween the reserves for the relevant contracts issued prior to 2021 computed under the old basis ($110) and the reserves for such contracts computed under the new basis ($120). For purposes of determining any net increase or net decrease in reserves in taxable year 2021 under section 807(a) or (b), IC’s closing balance of life insurance reserves computed under section 807(d) with respect to the relevant contracts is $110 for contracts issued prior to 2021 (computed on the old basis) and $15 for contracts issued during 2021 (computed on the new basis). IC’s opening bal­ ance in 2022 for life insurance reserves for the rele­ vant contracts is $135 (computed on the new basis).

(4) Example 4 —(i) Facts . The facts are the same as in paragraph (d)(3) of this section (the facts in Example 3 ), except that IC is an insurance company that is not a life insurance company. IC is required to compute taxable income under section 832.

(ii) Analysis . IC must take into account under section 481 and the administrative procedures pre­ scribed by the Commissioner the $10 difference be­ tween the reserves for the relevant contracts issued prior to 2021 computed under the old basis ($110) and the reserves for such contracts computed under the new basis ($120). For purposes of determining the premiums earned on insurance contracts during the taxable year as described in section 832(b)(4) for the year of change, the life insurance reserves at the end of the taxable year are $110 for contracts issued prior to 2021 (computed on the old basis) and $15 for contracts issued during 2021 (computed on the new basis). For purposes of determining the premi­ ums earned on insurance contracts during the taxable year as described in section 832(b)(4) for the taxable year following the year of change, the life insurance reserves at the end of the preceding taxable year (the

year of change) with respect to relevant contracts are $135 (computed on the new basis).

(e) Applicability date . The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . However, a taxpayer may choose to apply the rules of this section for taxable years begin­ ning after December 31, 2017, the effec­ tive date of the revision of section 807 by Public Law 115-97, and ending before the first taxable year that begins on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . See section 7805(b)(7).

§1.809-2 [Removed]

Par. 12. Section 1.809-2 is removed.

§1.809-5 [Amended]

Par. 13. Section 1.809-5 is amended by removing the language “and §1.810-3” from the last sentence of paragraph (a)(5)(iii).

§1.810-3 [Removed]

Par. 14. Section 1.810-3 is removed. Par. 15. Section 1.816-1 is added before the undesignated center heading “Miscel­ laneous Provisions” to read as follows:

§1.816-1 Life insurance reserves .

(a) Definition of life insurance reserves . Except as provided in section 816(h), a reserve that meets the requirements of section 816(b)(1) and (2) will not be dis­ qualified as a life insurance reserve solely because the method used to compute the reserve takes into account other factors, provided that the method used to compute the reserve is a tax reserve method as de­ fined in section 807(d)(3) and that such reserve is not an asset adequacy reserve as described in §1.807-1(a).

(b) Applicability date . The section applies to taxable years beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. However, a taxpayer may choose to apply the rules of this section for taxable years beginning after Decem­ ber 31, 2017, the effective date of the revi­ sion of section 807 by Public Law 115-97,

Bulletin No. 2020–17 679 April 20, 2020

and ending before the first taxable year that begins on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . See section 7805(b)(7).

§1.817A-0 [Removed]

(l) Applicability date . Except as pro­ vided in this paragraph (l), paragraph (c) of this section applies to any taxable year beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . How­ ever, a taxpayer may choose to apply para­ graph (c) of this section to any original Federal income tax return (including any amended return filed on or before the due date (including extensions) of such origi­ nal return) timely filed on or after [DATE FINAL REGULATIONS ARE PUB- LISHED IN THE FEDERAL REGIS- TER] . For taxable years beginning be­ fore [ DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] see paragraph (c) of this section as contained in 26 CFR part 1 in effect on April 1, 2019.

PART 301—PROCEDURE AND ADMINISTRATION

Par. 22. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *

§301.9100-6T [Amended]

Par. 16. Section 1.817A-0 is removed. Par. 17. Section 1.817A-1 is amended by:

  1. Revising the heading to paragraph (b) and paragraph (b)(1).

  2. Removing paragraph (b)(2).

  3. Redesignating paragraphs (b)(3) and (4) as paragraph (b)(2) and (3).

  4. In newly redesignated paragraph (b) (3):

i. Revising the first sentence. ii. Removing the word “None” in the second sentence and adding “Neither” in its place.

  1. Removing paragraph (b)(5)
  2. Revising paragraph (d). The revisions read as follows:

§1.817A-1 Certain modified guaranteed contracts.


(b) Applicable interest rates for certain non-equity-indexed modified guaranteed contracts —(1) Tax reserves during tempo- rary guarantee period under section 807(c) (3) . An insurance company is required to determine the tax reserves for certain MGCs under section 807(c)(3). During the temporary guarantee period of such an MGC that is a non-equity-indexed MGC, the applicable interest rate to be used is the current market rate, as defined in paragraph (a)(5) of this section. For periods after the end of such a temporary guarantee period, section 807(c)(3) is not modified when ap­ plied to a non-equity indexed MGC. Sec­ tion 807(c)(3) is not affected by the defi­ nition of current market rate contained in paragraph (a)(5) of this section once the temporary guarantee period has expired.


(3) Periods after the end of the tempo- rary guarantee period . For periods after the end of the temporary guarantee peri­ od, sections 807(c)(3) and 811(d) are not modified when applied to non-equity-in­ dexed MGCs. * * *


(d) Applicability dates . Paragraph (b) of this section applies to taxable years beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . How­ ever, a taxpayer may choose to apply the rules of paragraph (b) of this section for taxable years beginning after December 31, 2017, the effective date of the revision of section 807 by Public Law 115-97, and ending before the first taxable year that begins on or after [DATE FINAL REGU- LATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] . See section 7805(b)(7). For taxable years beginning before [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER], see paragraph (b) of this section as contained in 26 CFR part 1 re­ vised as of April 1, 2019.

§1.818-2 [Amended]

Par. 18. Section 1.818-2 is amended by removing paragraph (c).

§1.818-4 [Removed and Reserved]

Par. 19. Section 1.818-4 is removed and reserved.

§1.848-1 [Amended]

Par. 20. Section 1.848-1 is amended by removing the language “section 807(e) (4)” in paragraph (b)(2)(i) and adding the language “section 807(e)(3)” in its place.

Par. 21. Section 1.6012-2 is amended by:

  1. In the second sentence of paragraph (c)(1)(i), removing “Except as provided in paragraph (c)(4) of this section, such” and adding “Such” in its place.

  2. In the third sentence of paragraph (c)(2), removing “Except as provided in paragraph (c)(4) of this section, such” and adding “Such” in its place.

  3. Removing paragraph (c)(4).

  4. Redesignating paragraph (c)(5) as paragraph (c)(4).

  5. Revising paragraph (l). The revision reads as follows.

§1.6012-2 Corporations required to make returns of income.


Par. 25. Section 301.9100-6T is amend­ ed by:

  1. Removing from the table in para­ graph (a)(1) the three entries for “211” and the entries for “216(c)(1),” “216(c) (2),” “217(i),” and “217(l)(2)(B).”

  2. Removing and reserving paragraph (a)(2)(iii).

  3. Removing paragraph (a)(3)(v).

  4. In paragraph (a)(4): i. Removing “211 (Code section 810(b) (3)), 216(c) (1) and (2), 217(l),” from the first sentence.

ii. Removing “211 (Code sections 806(d)(4), and 807(d)(4)(C)), 217(i),” from the second sentence.

iii. Removing the last sentence.

Sunita Lough, Deputy Commissioner for Services

and Enforcement.

(Filed by the Office of the Federal Register on April 1, 2019, 8:45 a.m., and published in the issue of the Federal Register for April 2, 2019, 85 F.R. 18496)

April 20, 2020 680 Bulletin No. 2020–17

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