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Tax Reform

Weekly IRS Roundup January 18 – January 22, 2021

by McDermott Will & Emery | Jan 27, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

On January 20, President Biden’s chief of staff, Ronald Klain, issued a memorandum freezing the publication of rules in the Federal Register pending additional review by presidential designees or appointees. As a result, there may be delays in the official publication of pending IRS actions.

January 19, 2021: The IRS released Notice 21-08 providing a waiver of the addition to tax for underpayment of estimated income tax by individual taxpayers, where the underpayment is attributable to the amendment to section 461(l)(1)(B) contained in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

January 19, 2021: The IRS issued Rev. Rul. 21-04 updating the applicable federal rate and various other prescribed rates for February 2021.

January 19, 2021: The IRS issued Notice 21-09 updating weighted average interest rates, yield curves and segment rates.

January 19, 2021: The IRS released Notice 21-06 waiving the requirement to file information returns or furnish payee statements related to certain COVID-19 relief programs.

January 19, 2021: The IRS posted Notice 21-11 extending relief for employers to withhold and pay certain taxes because of the ongoing COVID-19 pandemic.

January 19, 2021: The IRS posted Notice 21-10 extending and providing additional relief for Qualified Opportunity Funds and their investors because of the ongoing COVID-19 pandemic

January 19, 2021: The IRS announced Notice 21-13 providing relief for partnerships from certain penalties related to the reporting of partners’ beginning capital account balances.

January 22, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 22, 2021: The IRS released Internal Revenue Bulletin 2021-4, dated January 25, 2021, containing the following highlights: Rev. Proc. 2021-8 (Exempt Organizations); TD 9937 (Employee Plans); Rev. Proc. 2021-10 (Income Tax); Rev. Rul. 2021-2 (Income Tax); Ann. 2021-1 (Tax Conventions).

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

Weekly IRS Roundup January 11 – January 15, 2021

by McDermott Will & Emery | Jan 20, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 11, 2021 – January 15, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

January 11, 2021: The IRS released TD 9948 containing final regulations relating to the excise taxes imposed on certain amounts paid for transportation of persons and property by air.

January 11, 2021: The IRS released TD 9938 setting forth final regulations related to the excise tax on remuneration in excess of $1 million and any excess parachute payment paid by certain tax-exempt organizations to covered employees.

January 12, 2021: The IRS released TD 9946 containing final regulations related to the deduction and reporting of certain fines, penalties and other amounts.

January 13, 2021: The IRS released TD 9949 providing final regulations concerning the application of the employer shared responsibility provisions and certain nondiscrimination rules to health reimbursement arrangements and certain other health plans.

January 14, 2021: The IRS released Rev. Proc. 21-11 providing methods for calculating W-2 wages for purposes of the wage limitation for the section 199A(g) deduction.

January 14, 2021: The IRS released Rev. Proc. 21-12 extending, in light of the continuing COVID-19 pandemic, the expiration date relevant to the application of certain safe harbors protecting the tax status of certain real estate mortgage investment conduits (REMICs) and investment trusts.

January 15, 2021: The IRS released Rev. Rul. 21-03 providing tables of covered compensation related to the contribution and benefit bases under the Social Security Act.

January 15, 2021: The IRS released Notice 21-12 providing temporary relief, due to the continuing COVID-19 pandemic, from certain requirements for qualified low-income housing projects and qualified residential rental projects.

January 15, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 15, 2021: The IRS released Internal Revenue Bulletin 2021-3, dated January 19, 2021, containing the following highlights: Notice 2021-7 (Administrative, Employment); TD 9932 (Employee Plans, Income Tax); REG-114615-16 (Excise Tax); Notice 2021-2 (Income Tax); Notice 2021-5 (Income Tax); Rev. Proc. 2021-9 (Income Tax); TD 9939 (Income Tax); TD 9941 (Income Tax); and TD 9942 (Income Tax).

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

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 [...]

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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.

Let’s All Stop and Reflect for a Moment

by McDermott Will & Emery | Dec 21, 2020 | Appellate Courts, Tax Reform, Trial Courts

In a recent article for the American Bar Association’s ABA Tax Times, McDermott partner Andrew R. Roberson reflected on 2020 and the importance of giving back.

“From COVID-19 to the Black Lives Matter movement; from home office and Zoom to remote learning for students; and so on—these events have impacted us all, both on professional and personal levels.”

Access the 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.