IRS Guidance Archives - Page 27 of 113

IRS Guidance

Weekly IRS Roundup December 28, 2020 – January 8, 2021

by McDermott Will & Emery | Jan 14, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 29, 2020: The IRS released Revenue Procedure 21-09 providing a procedure for a trade or business that manages or operates a qualified residential living facility to elect to be treated as a real property trade or business for purposes of section 163(j).

December 31, 2020: The IRS issued Notice 21-05 clarifying and modifying the beginning of construction requirement for qualified facility and energy property projects under sections 45 and 48.

December 31, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

December 31, 2020: The IRS released Internal Revenue Bulletin 2021-1, dated January 4, 2021, containing the following highlights: Rev. Proc. 2021-1 (Administrative); Rev. Proc. 2021-2 (Administrative); Rev. Proc. 2021-3 (Administrative); Rev. Proc. 2021-4 (Employee Plans); Rev. Proc. 2021-5 (Exempt Organizations); and Rev. Proc. 2021-7 (Income Tax).

January 4, 2021: The IRS issued Notice 21-07 providing temporary relief for employers and employees using the automobile lease valuation rule due to the COVID-19 pandemic.

January 5, 2021: The IRS issued Revenue Procedure 21-08 modifying Revenue Procedure 2021-5 to provide that the exclusive means of submitting Form 1024-A, after the 90-day transition relief period, is through the electronic submission process.

January 5, 2021: The IRS issued Revenue Procedure 21-10 providing procedures for issuers of tax-advantaged bonds who received adverse determinations by the Office of Tax Exempt Bonds to request an administrative appeal from the Independent Office of Appeals.

January 5, 2021: The IRS released TD 9943 containing the final regulations under section 163(j) related to the limitation on the deduction for business interest expense.

January 6, 2021: The IRS issued Revenue Ruling 21-02 declaring Notice 2020-32 and Rev. Rul. 2020-27, both of which provided that certain taxpayers could not deduct expenses related to loans forgiven under the Paycheck Protection Program, as obsolete.

January 6, 2021: The IRS released TD 9944 containing the final regulations under section 45Q related to the credit for carbon oxide sequestration.

January 7, 2021: The IRS released TD 9945 containing the final regulations under section 1061 related to the characterization of gains for taxpayers directly or indirectly holding applicable partnership interests in connection with the performance of substantial services.

January 8, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 8, 2021: The IRS released Internal Revenue Bulletin 2021-2, dated January 11, 2021, containing the following highlights: TD 9940 (Administrative); Notice 2021-03 (Employee Plans); Notice 2021-04 (Excise [...]

Continue Reading

Weekly IRS Roundup December 21 – December 26, 2020

by McDermott Will & Emery | Dec 30, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 21 – December 26, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 21, 2020: The IRS released TD 9941 containing final regulations regarding the timing of income inclusion under an accrual method of accounting, including the treatment of advance payments for goods, services and certain other items.

December 22, 2020: The IRS issued Notice 21-02 providing the standard mileage rate for 2021.

December 22, 2020: The IRS issued Notice 21-03 extending temporary relief from the physical presence requirement for spousal consents under certain qualified retirement plans.

December 22, 2020: The IRS issued Notice 21-04 extending temporary relief for certain dyed fuel removals related to the West Shore Pipeline shutdown.

December 23, 2020: The IRS released TD 9942 containing final regulations implementing simplifications to certain tax accounting provisions for certain businesses with annual gross receipts less than $25 million (as adjusted for inflation).

December 24, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

December 26, 2020: The IRS released Internal Revenue Bulletin 2020-53, dated December 28, 2020, containing the following highlights: Rev. Proc. 2020-55 (Administrative); Notice 2020-88 (Administrative, Income Tax); Rev. Proc. 2020-54 (Administrative, Income Tax); Notice 2020-86 (Employee Plans); Notice 2020-87 (Employee Plans); Notice 2020-78 (Income Tax); TD 9921 (Income Tax).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

Weekly IRS Roundup December 14 – December 18, 2020

by McDermott Will & Emery | Dec 23, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 14 – December 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 14, 2020: The IRS released Notice 2020-88 updating and amplifying procedures for Phase III of the section 48A advanced coal credit.

December 16, 2020: The IRS issued Revenue Ruling 21-01 providing various rates for determining the issue price of certain debt instruments issued for property.

December 16, 2020: The IRS issued Notice 21-01 delaying mandatory e-filing of Form 4720 by private foundations and announcing certain other changes.

December 18, 2020: The IRS released TD 9932 containing final regulations under Section 162(m) related to the employer deduction for certain employee remuneration in excess of $1 million.

December 18, 2020: The IRS released Internal Revenue Bulletin 2020-52, dated December 21, 2020, containing the following highlights: Rev. Rul. 2020-81 (Administrative); TD 9912 (Administrative); TD 9933 (Exempt Organizations); TD 9934 (Income Tax); TD 9935 (Income Tax).

December 18, 2020: The IRS released Practice Units on “Determining Liability Allocations” and “Recourse vs. Nonrecourse Liabilities” relating to partnership audits.

December 18, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

2020’s Key Tax Controversy Developments

by Kevin Spencer and McDermott Will & Emery | Dec 16, 2020 | Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Transfer Pricing Resource, Trial Courts

In the face of the pandemic and all the challenges that came with 2020, tax controversy marched on. In this article, we explore several important cases, including one of the most closely watched Supreme Court cases, CIC Services LLC v. Internal Revenue Service, which raises important questions regarding the scope of the Anti-Injunction Act and impacts the ability of taxpayers to engage in preenforcement challenges to regulations.

We also look into the latest updates in the transfer pricing area, changes to the Compliance Assurance Process, what to expect during the audit of a campaign issue and more.

Read the full article.

Weekly IRS Roundup December 7 – December 11, 2020

by McDermott Will & Emery | Dec 15, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 7 – December 11, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 7, 2020: The IRS released TD 9937 related to rollover rules for qualified plan loan offset amounts.

December 9, 2020: The IRS issued Notice 2020-86 providing guidance on sections 102 and 103 of the SECURE Act with respect to safe harbor plans.

December 9, 2020: The IRS released TD 9939 containing final regulations addressing the elimination of the deduction under section 274 for expenses related to certain transportation and commuting benefits provided by employers to their employees.

December 9, 2020: The IRS updated an Issue Snapshot providing an overview of the tax implications of settlements and judgments.

December 9, 2020: The IRS updated an Issue Snapshot detailing worker classification when a taxpayer files both Form W-2 and Form 1099-MISC for a worker for the same year.

December 11, 2020: The IRS issued Notice 2020-87 updating certain weighted average interest rates, yield curves and segment rates.

December 11, 2020: The IRS issued Notice 2020-78 providing transition relief to certain employers claiming the Work Opportunity Tax Credit (WOTC) under section 51.

December 11, 2020: The IRS released Internal Revenue Bulletin 2020-51, dated December 14, 2020, containing the following highlights: REG-123652-18 (Administrative); Notice 2020-85 (Employee Plans); Notice 2020-84 (Excise Tax); and TD 9926 (Income Tax).

December 11, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, D.C. office for this week’s roundup.

Weekly IRS Roundup November 30 – December 4, 2020

by McDermott Will & Emery | Dec 8, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 30, 2020: After releasing a pre-publication draft in early October, the IRS published TD 9926 in the Federal Register, which provides final regulations regarding withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the United States under section 1446(f).

December 3, 2020: The IRS released Rev. Rul. 2020-28 related to the determination of the rate of interest under section 6621.

December 3, 2020: The IRS released Draft Instructions to Form 8992 related to the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).

December 4, 2020: The IRS issued REG-111950-20 regarding passive foreign investment companies (PFICs) and the treatment of qualified improvement property under the alternative depreciation system.

December 4, 2020: The IRS issued TD 9936 regarding PFICs.

December 4, 2020: The IRS issued the Fall 2020 Statistics of Income Bulletin providing data about tax and information returns. The Bulletin highlights high-income tax returns for Tax Year 2017 and partnership returns for Tax Year 2018.

December 4, 2020: The IRS issued a Statement warning that employers will experience delays in receiving payments associated with Form 7200 Advance Payment of Employer Credits.

December 4, 2020: The IRS released Internal Revenue Bulletin 2020-50, dated December 7, 2020, containing the following highlights: Notice 2020-83 (Employee Plans); TD 9923 (Exempt Organizations); Rev. Proc. 2020-51 (Income Tax); Rev. Rul. 2020-26 (Income Tax); Rev. Rul. 2020-27 (Income Tax).

December 4, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

Weekly IRS Roundup November 23 – November 27, 2020

by McDermott Will & Emery | Dec 1, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 23, 2020: The IRS released TD 9935, providing final regulations implementing statutory changes to the treatment of like-kind exchanges.

November 23, 2020: The IRS issued a News Release announcing a research partnership to improve IRS procurement operations.

November 24, 2020: The IRS released Notice 2020-84 announcing the adjusted applicable dollar amount for calculating the fee imposed by sections 4375 and 4376 for certain health plans.

November 25, 2020: The IRS updated FAQs providing guidance on What Is an Eligible Employer for COVID-19-related tax credit purposes and How to Claim the Credits.

November 27, 2020: The IRS released Internal Revenue Bulletin 2020-49, dated November 30, 2020, containing the following highlights: Notice 2020-81 (Employee Plans); Notice 2020-82 (Employee Plans); TD 9929 (Employee Plans); TD 9930 (Employee Plans); REG-101657-20 (Income Tax); Rev. Proc. 2020-48 (Income Tax); TD 9922 (Income Tax); and Notice 2020-75 (Income Tax).

November 27, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

Weekly IRS Roundup November 16 – November 20, 2020

by McDermott Will & Emery | Nov 23, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 16, 2020 – November 20, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 16, 2020: The IRS released Notice 2020-82 related to the due date for certain contributions to defined benefit plans.

November 16, 2020: The IRS released Revenue Ruling 2020-26 updating the applicable federal rate and various other prescribed rates for December 2020.

November 16, 2020: The IRS released Notice 2020-81 updating weighted average interest rates, yield curves, and segment rates.

November 18, 2020: The IRS released Revenue Ruling 2020-27 related to deductions for expenses paid with Paycheck Protection Program (PPP) loans.

November 18, 2020: The IRS released Revenue Procedure 2020-51 providing a safe harbor for deductions for expenses paid with PPP loans when loan forgiveness is denied or the taxpayer forgoes forgiveness.

November 19, 2020: The IRS released TD 9933 containing final regulations to provide guidance regarding unrelated business taxable income of exempt organization.

November 20, 2020: The IRS released Notice 2020-83 announcing the Required Amendments List for qualified retirement plans and section 403(b) retirement plans.

November 20, 2020: The IRS released TD 9934 containing final regulations to coordinate the extraordinary disposition rule under section 245A with the disqualified basis and disqualified payment rules under section 951A.

November 20, 2020: The IRS released Internal Revenue Bulletin 2020-47, dated November 23, 2020, containing the following highlights: Rev. Proc. 2020-49 (Administrative); REG-122462-20 (Employee Plans); Rev. Proc. 2020-47 (Employee Tax); Rev. Rule. 2020-25 (Income Tax); Rev. Proc. 2020-50 (Income Tax); T.D. 9919 (Income Tax); and T.D. 9931 (Temporary Regulation).

November 20, 2020: The IRS released an audit technique guide for conservation easements.

November 20, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, D.C. office for this week’s roundup.

Weekly IRS Roundup November 9 – November 13, 2020

by McDermott Will & Emery | Nov 18, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 9, 2020: The IRS released Notice 2020-75 announcing the IRS’ intention to issue proposed regulations permitting partnerships and S corporations to deduct certain state and local income taxes in computing non-separately stated taxable income.

November 12, 2020: The IRS released draft instructions for Form 1120-F Schedule H related to deductions allocated to effectively connected income (ECI) under Treas. Reg. § 1.861-8. Additionally, the IRS released draft instructions for Form 1120-F Schedule I related to interest expense allocation under Treas. Reg. § 1.882-5.

November 13, 2020: The IRS published corrections to TD 9909 related to the limitation on deduction for dividends received from certain foreign corporations.

November 13, 2020: The IRS posted a News Release announcing that to protect business taxpayers from identity theft, the IRS would mask sensitive data on business tax transcripts.

November 13, 2020: The IRS released Internal Revenue Bulletin 2020-47, dated November 16, 2020, containing the following highlights: Announcement 2020-19 (Administrative); Notice 2020-76 (Administrative); Notice 2020-80 (Employee Plans); Rev. Rul. 2020-23 (Employee Plans); REG-119890-18 (Income Tax); and TD 9927 (Income Tax).

November 13, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

Weekly IRS Roundup November 2 – November 6, 2020

by McDermott Will & Emery | Nov 10, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 2, 2020 – November 6, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 2, 2020: The IRS announced COVID-19-related changes to tax debt collection procedures to provide taxpayer relief.

November 4, 2020: The IRS released Rev. Proc. 2020-48 regarding discount factors used by insurance companies for the 2020 accident year.

November 4, 2020: The IRS released Rev. Proc. 2020-49 regarding the public approval requirement for tax-exempt qualified private activity bonds.

November 5, 2020: The IRS released Rev. Rul. 2020-23 related to certain distributions upon termination of a section 403(b) retirement plan.

November 5, 2020: The IRS updated FAQs related to qualified intermediaries, withholding for foreign partnerships and withholding for foreign trusts.

November 6, 2020: The IRS and US Department of the Treasury released Rev. Proc. 2020-50 related to election relief for additional first-year depreciation deductions for certain property.

November 6, 2020: The IRS released Internal Revenue Bulletin 2020-46, dated November 9, 2020, containing the following highlights: Rev. Proc. 2020-45 (Administrative, Estate Tax, Excise Tax, Gift Tax, Income Tax); Notice 2020-79 (Employment Plans); and TD 9914 (Income Tax).

November 6, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.