HIGHLIGHTS Bulletin No. 2017–49 OF THIS ISSUE December 4, …

HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2017?23, page 546. Section 995(f) of the Internal Revenue Code requires the IRS to annually publish a "base period T-bill rate" with which a shareholder of an interest charge domestic international sales corporation (IC-DISC) calculates the interest due on their IC-DISCrelated deferred tax liability for the year. Revenue Ruling 2017?23 sets forth the base period T-bill rate as determined by the Office of Debt Management within the Treasury Department for the period ending September 30, 2017, and provides a table of factors compounded daily for taxpayers with short or alternative taxable years.

Rev. Rul. 2017?24, page 556. Federal rates; adjusted federal rates; adjusted federal longterm rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2017. Table 6, however, contains the 2018 interest rate for purposes of sections 846 and 807.

Bulletin No. 2017? 49 December 4, 2017

Finding Lists begin on page ii.

The IRS Mission

Provide America's taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.

against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.--1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.

Part II.--Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports.

Part III.--Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury's Office of the Assistant Secretary (Enforcement).

Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned

Part IV.--Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

December 4, 2017

Bulletin No. 2017? 49

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 995--Taxation of DISC Income to Shareholders 2017 Base Period T-Bill Rate. The "base period T-bill rate" for the period ending September 30, 2017, is published as required by section 995(f) of the Internal Revenue Code.

Rev. Rul. 2017?23

Section 995(f)(1) of the Internal Revenue Code provides that a shareholder of a domestic international sales corporation ("DISC") shall pay interest each taxable year in an amount equal to the product of the "shareholder's DISC-related deferred tax liability" for the year (as defined in section 995(f)(2)) and the "base period T-bill rate." Under section 995(f)(4), the base period T-bill rate is the annual rate of interest determined by the Secretary to be equivalent to the average of the 1-year constant maturity Treasury yields, as published by the Board of Governors of the Federal Reserve System, for the 1-year period ending on September 30 of the

calendar year ending with (or the most recent calendar year ending before) the close of the taxable year of the shareholder.

The base period T-bill rate for the period ending September 30, 2017, is 1.01 percent.

Pursuant to section 6622 of the Internal Revenue Code, interest must be compounded daily. The table below provides factors for compounding the 2017 base period T-bill rate daily for any number of days in the shareholder's taxable year (including for a 52?53 week accounting period). To compute the amount of the interest charge for the shareholder's taxable year, multiply the amount of the shareholder's DISCrelated deferred tax liability for that year by the base period T-bill rate factor corresponding to the number of days in the shareholder's taxable year for which the interest charge is being computed. Generally, one would use the factor for

365 days. One would use a different factor only if the shareholder's taxable year for which the interest charge is being determined is a short taxable year, if the shareholder uses a 52?53 week taxable year, or if the shareholder's taxable year is a leap year.

For the base period T-bill rates for periods ending in prior years, see Rev. Rul. 2017? 01, 2017? 03 IRB 377; Rev. Rul. 2015?26, 2015? 49 IRB 696; Rev. Rul. 2014 ?33, 2014 ?52 IRB 957; Rev. Rul. 2013?24, 2013? 49 IRB 594; and Rev. Rul. 2012?22, 2012? 48 IRB 565.

DRAFTING INFORMATION

The principal author of this revenue ruling is L. Ulysses Chatman of the Office of Associate Chief Counsel (International). For further information regarding the revenue ruling, contact Mr. Chatman at (202) 317-6939 (not a toll-free number).

DAYS 1 2 3 4 5

ANNUAL RATE, COMPOUNDED DAILY

1.01 PERCENT FACTOR

0.000027671 0.000055343 0.000083016 0.000110690 0.000138364

6

0.000166039

7

0.000193715

8

0.000221391

9

0.000249069

10

0.000276747

11

0.000304426

12

0.000332105

13

0.000359786

14

0.000387467

15

0.000415149

16

0.000442832

17

0.000470515

18

0.000498199

December 4, 2017

546

Bulletin No. 2017? 49

DAYS 19 20

21 22 23 24 25

26 27 28 29 30

31 32 33 34 35

36 37 38 39 40

41 42 43 44 45

46 47 48 49 50

51 52 53 54 55

Bulletin No. 2017? 49

ANNUAL RATE, COMPOUNDED DAILY

1.01 PERCENT FACTOR

0.000525884 0.000553570

0.000581257 0.000608944 0.000636632 0.000664321 0.000692011

0.000719701 0.000747392 0.000775084 0.000802777 0.000830470

0.000858164 0.000885859 0.000913555 0.000941252 0.000968949

0.000996647 0.001024346 0.001052045 0.001079746 0.001107447

0.001135149 0.001162851 0.001190555 0.001218259 0.001245964

0.001273670 0.001301376 0.001329083 0.001356791 0.001384500

0.001412210 0.001439920 0.001467631 0.001495343 0.001523055

547

December 4, 2017

DAYS 56 57 58 59 60

61 62 63 64 65

66 67 68 69 70

71 72 73 74 75

76 77 78 79 80

81 82 83 84 85

86 87 88 89 90

91 92 93

December 4, 2017

ANNUAL RATE, COMPOUNDED DAILY

548

1.01 PERCENT FACTOR

0.001550769 0.001578483 0.001606198 0.001633914 0.001661630

0.001689347 0.001717065 0.001744784 0.001772503 0.001800224

0.001827945 0.001855667 0.001883389 0.001911113 0.001938837

0.001966562 0.001994287 0.002022014 0.002049741 0.002077469

0.002105197 0.002132927 0.002160657 0.002188388 0.002216120

0.002243853 0.002271586 0.002299320 0.002327055 0.002354790

0.002382527 0.002410264 0.002438002 0.002465741 0.002493480

0.002521220 0.002548961 0.002576703

Bulletin No. 2017? 49

 ................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download