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IRS Publishes Technical Guidance on Five Issues

The IRS recently released information about a number of announcements, rulings, and notices. Five of those items, Announcement 2014-34, Revenue Ruling 2014-29, Announcement 2014-38, Announcement 2014-41, and Notice 2014-77,  are listed below.

Announcement 2014-34 addresses the transfer of certain technical responsibility for issues involving exempt organizations, qualified retirement plans, and individual retirement annuities and accounts (IRAs) to the Office of Chief Counsel that will occur with the realignment of the Tax Exempt and Government Entities Division (TE/GE).  As a result of the realignment occurring at the beginning of 2015, the technical responsibility for preparing revenue rulings, revenue procedures, and certain other forms of published guidance, and issuing technical advice and certain letter rulings, will shift from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities) (TEGE Counsel).  The annual revenue procedures addressing these matters will be updated in January 2015 to reflect this realignment.

Announcement 2014-34 will be published in Internal Revenue Bulletin 2014-51 on Dec. 15.

Revenue Ruling 2014-29 provides the interest rates for the first Calendar Quarter of 2015 (beginning Jan. 1), a draft press release and the early drop instructions for this ruling.

Revenue Ruling 2014-29 will be published in Internal Revenue Bulletin 2014-52 on Dec. 22.

Announcement 2014-38 provides guidance with respect to jurisdictions that are treated as if they had a FATCA intergovernmental agreement (IGA) in effect pursuant to Announcement 2014-17, 2014-18 I.R.B. 1001, but that do not sign the IGA before Dec. 31, 2014. Announcement 2014-38 provides that a jurisdiction that is treated as if it had an IGA in effect, but that has not yet signed an IGA, retains such status beyond Dec. 31, 2014, provided that the jurisdiction demonstrates firm resolve to sign the IGA as soon as possible.  After Dec. 31, 2014, Treasury will review the list of jurisdictions having an agreement in substance on a monthly basis to assess whether it continues to be appropriate to treat such a jurisdiction as if it had an IGA in effect or whether a jurisdiction should be removed from the list.

Announcement 2014-38 will be published in Internal Revenue Bulletin 2014-51 on Dec 15.

Announcement 2014-41 extending to June 30, 2015, the deadline for submitting on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the plans’ second six-year remedial amendment cycle.  This announcement also provides a two day extension (from Saturday, January 31, 2015, to Monday, February 2, 2015) for Cycle D on-cycle submissions (primarily individually designed plans including multiemployer plans).

Announcement 2014-41 IRB 2014-52, dated December 22, 2014.

Notice 2014-77 contains the 2014 Cumulative List of Changes in Plan Qualification Requirements (2014 Cumulative List) described in section 4 of Rev. Proc. 2007-44, 2007-2 C.B. 54.  The 2014 Cumulative List is to be used by plan sponsors and practitioners submitting determination letter applications for plans during the period beginning February 1, 2015 and ending January 31, 2016.

Notice 2014-77 will be in IRB 2014-52, dated December 22, 2014.

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Source:  Internal Revenue Service

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