Internal Revenue Bulletin: 2015-12

To determine wagering gain or loss from electronically tracked slot machine play at the end of a session, a player must: The form can be submitted electronically or on paper. Under IRS Revenue Procedure , an amateur gambler must record the following information in a log or similar record:. As a result, the IRS is waiving the penalty for failing to make estimated tax payments for any farmer or fisherman who, due to this delay, files their return and pays any tax due by Wednesday, April 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 against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

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Wooten said the new location next door provides space for a restaurant, more parking and a seven-day-a-week dining operation, which wasn't the case at the market. Market hours are posted as 10 a. Tuesday-Thursday and 9 a. That left the restaurant closed Sundays, Mondays and evenings. Wooten said the parking capacity will be about 1, spaces, including a lot next to the U.

The restaurant, which has yet to be named, can operate for lunch and dinner, seven days a week, with a waterfront view in Mayport that Wooten said is "breathtaking. Wooten said the waterfront Safe Harbor market and restaurant began as a block building that sold bait, but soon outgrew itself.

He said he has been working with Pack for 23 years and is the buyer for the market. He will be in charge of the Safe Harbor Seafood market and a partner in the restaurant. Wooten said the details of the investment cost and seating capacity for the new restaurant are not finalized.

The more of the world you own, the larger the army that you can muster. Command HQ is now available exclusively at SafeHarborGames and can now be installed easily and played for free by going to the SafeHarborGames website. SafeHarborGames Cribbage is a unique card game for two and four players that involves playing and grouping cards to gain points. SafeHarborGames Cribbage features the full Cribbage board.

The object of the game is to score the most points by making card combinations of fifteen using pairs, runs and flushes.

SafeHarborGames Cribbage has several distinctive features: In the SHG version, we show the cribbage board with the pegs denoting the proper scores, but we also show the scores next to the Player's nicks at the top and bottom, respectively. SafeHarborGames supports the classic game of Euchre to put your card skills to the test. Pair up with a partner and bid on being the trump maker or the defender.

Euchre your opponents by preventing them from taking three tricks. Be the first team to score 11 points to win in Free Online Euchre game. SafeHarborGames supports the classic game of Gin Rummy to put your card skills to the test. Test your skills of building sets and runs and Knocking or Ginning your opponent to win. Hearts is played with four 4 players using a standard card deck without jokers. Cards range from Ace highest to deuce 2 lowest.

The entire deck is dealt so each player starts the hand with 13 cards. The objective is to have the lowest score when one of the player's score reaches or exceeds Points, ending the game. At SafeHarborGames, the game is displayed so that each player's nest is to his lower right.

Its origin can be traced to the mid 19th century, when it was derived from the similar French game of bezique. Pinochle became a mainstay in the United States during the late s. At first , most variations were for two and three players. Since the s, however, the most frequently played version is double deck for partners.

Spades is played with four players people or bots , where players sitting opposite each other play as a team. The deal rotates clockwise around the table. A standard deck of 52 cards is used aces high , and each player is dealt 13 cards. The object of the game is to win points for taking the number of tricks that you and your partner bid. Open to all players in SafeHarborGames. Please join us for our Safe Harbor Casino Cruise. Sail along with us for a fun-filled day of games.

Just another way of showing our appreciation for your patronage and support. Dates, along with formats and hosting information will be listed.

Please join us in the Safe Harbor Game Regattas. We are going to have a special spooky lobby for all to enjoy!! This is SHG's way of wishing you and your family a safe and spooky Halloween!! Tournament formats and hosting information will be listed. The "Zoner's Reunion" is back! Because D cannot remember his social security number, D cannot complete and sign a Form W—9.

D returns to casino S and at 6 p. S generally uses the aggregate reporting method and in all cases where it is used, S complies with the requirements of this paragraph h.

For each of these two wins, an employee of S obtains the information from D required by this paragraph h:. In one session on Day 1, E won five reportable gambling winnings from five different bingo games at a casino T. T generally uses the aggregate reporting method and in all cases where it is used, T complies with the requirements of this paragraph h. Although E signed the entry in the record T maintains for payment of the first four reportable gambling winnings, E refuses to sign the entry in the record for the fifth payment of reportable gambling winnings.

T may use the aggregate reporting method for the first four payments of reportable gambling winnings to E. Accordingly, if T uses the aggregate reporting method under paragraph h of this section, T must prepare two Forms W—2G as follows: On the first Form W—2G, T must report the first four payments of reportable gambling winnings from bingo made to E on Day 1.

On the second Form W—2G, T must report the fifth payment of reportable gambling winnings from bingo made to E on Day 1. This section applies to payments of reportable gambling winnings from bingo, keno, slot machine play, and electronically tracked slot machine play made on or after the date these regulations are published as final regulations in the Federal Register.

For payments made before that date, other than payments from electronically tracked slot machine play, payors may rely on the provisions of these proposed regulations. This document contains proposed amendments to the consolidated return regulations. The proposed regulations would affect such corporations and the consolidated groups that they join or leave.

Written or electronic comments and requests for a public hearing must be received by June 4, Concerning the proposed regulations, Russell G. Jones, ; concerning the submission of comments or to request a public hearing, Oluwafunmilayo Funmi P. Taylor, not a toll-free number. This notice of proposed rulemaking contains proposed regulations that amend 26 CFR part 1 under section of the Internal Revenue Code Code.

Section authorizes the Secretary to prescribe regulations for corporations that join in filing a consolidated return, and it expressly provides that those rules may be different from the provisions of chapter 1 of subtitle A of the Code that would apply if those corporations filed separate returns.

S also must file a separate return including a consolidated return of another group that includes its items for the period during which it is not a member. The notice of proposed rulemaking that proposed the current end of the day rule 57 FR , Nov. There are two exceptions to the current end of the day rule.

No additional rule was necessary with respect to a qualified S corporation subsidiary QSub of an S corporation that joins a consolidated group. Commenters suggested that a rule providing this type of protection was most appropriate with respect to extraordinary items, and some commenters suggested that a rule similar to the current next day rule should operate unless the seller and buyer of S agreed otherwise. These proposed regulations address this concern as well as additional concerns with the current regulations, as summarized in this section 3.

The proposed regulations also add a rule previous day rule, described in section 3. In addition, the proposed regulations limit the scope of the end of the day rule, the next day rule, the S corporation exception, and the previous day rule to determining the period in which S must report certain tax items and determining the treatment of an asset or a tax item for purposes of sections h and as opposed to applying for all federal income tax purposes.

Additionally, the proposed regulations provide that short taxable years resulting from intercompany transactions to which section a applies intercompany section transactions are not taken into account in determining the carryover period for a tax item of the distributor or transferor member in the intercompany section transaction or for purposes of section a.

The proposed regulations make several other conforming and non-substantive changes to the current regulations as well. Finally, the proposed regulations add several examples to illustrate the proposed rules. The IRS and the Treasury Department note that neither the current regulations nor the proposed regulations are intended to supersede general rules in the Code and regulations concerning whether an item is otherwise includible or deductible.

The IRS and the Treasury Department view this interpretation of the current next day rule as inappropriate because it effectively would permit taxpayers to elect the income tax return on which these tax items are reported and therefore may not result in an allocation that clearly reflects taxable income.

The proposed next day rule is intended to eliminate the perceived electivity and the source of these controversies. As noted in section 2 of this preamble, the special rule for S corporations provides an exception to the end of the day rule if an S corporation joins a consolidated group. Although these proposed regulations retain the S corporation exception, the proposed regulations add a previous day rule that mirrors the principles of the proposed next day rule. To eliminate possible confusion arising from application of the current end of the day rule and related rules, these proposed regulations provide that the end of the day rule, the proposed next day rule, the S corporation exception, and the previous day rule apply for purposes of determining the period in which S must report its tax items, as well as for purposes of sections h and discussed in section 3.

The IRS and the Treasury Department also request comments as to whether any extraordinary item should be excluded, in whole or in part, from application of the next day rule and the previous day rule. This rule does not apply to certain foreign corporations the ownership of which may give rise to deemed income inclusions under the Code. The IRS and the Treasury Department request comments regarding this proposed amendment to the anti-avoidance rule. For purposes of section , the term recognized built-in loss RBIL means any loss recognized during the recognition period on the disposition of any asset held by the loss corporation immediately before the date of the section ownership change change date , to the extent the loss reflects a built-in loss on the change date.

Section h 2 B. The term recognition period means the five-year period beginning on the change date. Section h 7 A. Under the current consolidated return regulations, if a member distributes or transfers its assets to another corporation that is a member immediately after the distribution or transfer in an intercompany section transaction, and if the distributor or transferor member has a net operating loss carryover or a net capital loss carryover, the distributor or transferor member will not be treated as having a short taxable year for purposes of determining the years to which the loss may be carried.

In addition, these proposed regulations would expand these rules by providing that a short taxable year of the distributor or transferor member by reason of an intercompany section transaction is not counted as a separate taxable year for purposes of determining either the taxable years to which any tax attribute of the distributor or transferor member may be carried or the taxable years in which an adjustment under section a is taken into account.

No inference should be drawn from the proposed changes to these rules as to whether a short taxable year of a member resulting from an intercompany section transaction is counted under current law for purposes of determining the years to which a tax credit may be carried or in which a section adjustment is taken into account. The proposed regulations also eliminate a provision that could cause taxpayers to inadvertently miss a return filing deadline. If S goes out of existence during the consolidated return year in which S joins a group, its taxable year would end.

It is hereby certified that these regulations will not have a significant impact on a substantial number of small entities. This certification is based on the fact that the regulations apply only to transactions involving corporations that file consolidated federal income tax returns, and that such corporations tend to be larger businesses. Pursuant to section f of the Code, these regulations will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business.

All comments will be available for public inspection and copying. A public hearing may be scheduled if requested in writing by any person who timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place of the hearing will be published in the Federal Register. The principal author of these proposed regulations is Russell G. Immediately after the transfer, S and B are members of the same consolidated group.

By adding Examples 8 , 9 , and 10 to paragraph b 5. A In general — 1 End of the day rule. B Special rules for former S corporations — 1 Beginning of the day rule. D Coordination with sections and P purchases all of the stock of S, an accrual-basis, stand-alone C corporation, on June 30 pursuant to a stock purchase agreement. At the time of the stock purchase, S has outstanding nonqualified stock options issued to certain employees.

Under the option agreements, S is obligated to pay its employees certain amounts in cancellation of their stock options upon a change in control of S. Several days after the closing of the stock purchase, S pays its employees the amounts required under the option agreements. See paragraph b 2 ii C 9 of this section. Redemption that causes a change in status — a Facts. The redemption does not satisfy the requirements of section b and is treated under section d as a distribution to which section applies.

The end of the day rule does not apply for purposes of determining whether P and S are members of the same consolidated group immediately after the redemption. P may be entitled to a dividends received deduction under section c but see section e. The end of the day rule applies for purposes of determining the taxable year in which S must take into account its realized loss on the distribution of the land.

Extraordinary item of S corporation — a Facts. On July 1, P purchases all the stock of S, an accrual-basis corporation with an election in effect under section a. Paragraphs b 2 i and b 4 of this section apply to consolidated return years beginning on or after the date these regulations are published as final regulations in the Federal Register.

Otherwise, this paragraph b. Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified.

Compare with modified , below. Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion.

It is not used where a position in a prior ruling is being changed. Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position.

Compare with amplified and clarified , above. Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.

Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling or rulings. Thus, the term is used to republish under the Code and regulations the same position published under the Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used.

For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings.

After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

The following abbreviations in current use and formerly used will appear in material published in the Bulletin. A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc. A cumulative list of current actions on previously published items in Internal Revenue Bulletins —27 through —52 is in Internal Revenue Bulletin —52, dated December 28, The Introduction at the beginning of this issue describes the purpose and content of this publication.

The weekly Internal Revenue Bulletins are available at www. If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you.

For you and your family. Individuals abroad and more. EINs and other information. Get Your Tax Record. Bank Account Direct Pay. Debit or Credit Card. Payment Plan Installment Agreement. Standard mileage and other information. Instructions for Form Request for Transcript of Tax Return. Employee's Withholding Allowance Certificate. Employer's Quarterly Federal Tax Return.

Employers engaged in a trade or business who pay compensation. Popular For Tax Pros. Apply for Power of Attorney. Apply for an ITIN. Highlights of This Issue. Notice —22 Notice — Notice —21 Notice — Notice —23 Notice — Announcement —12 Announcement — Notice —18 Notice — Administrative, Procedural, and Miscellaneous. Internal Revenue Service Attn: PR Notice —21 Room P. Transitional Relief for Underpayment of Estimated Taxes. Items of General Interest.

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