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Tax Reform

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.

Weekly IRS Roundup October 26 – October 30, 2020

by McDermott Will & Emery | Nov 3, 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 October 26, 2020 – October 30, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 26, 2020: The IRS released Rev. Proc. 2020-45 regarding inflation adjusted items for 2021.

October 26, 2020: The IRS released Notice 2020-79, which sets out cost-of-living adjustments for benefits and contributions under qualified retirement plans.

October 27, 2020: The IRS published corrections to TD 9901 regarding the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).

October 30, 2020: The IRS and US Department of the Treasury released Proposed Regulations containing guidance on the average income test for the low-income housing tax credit. There is a public comment period until December 29, 2020.

October 30, 2020: The IRS released Internal Revenue Bulletin 2020-45, dated November 2, 2020, containing the following highlights: Rev. Proc. 2020-43 (Employee Plans); Rev. Proc. 2020-46 (Employee Plans); Notice 2020-77 (Employment Plans); Announcement 2020-40 (Income Tax); Rev. Proc. 2020-44 (Income Tax); Rev. Rul. 2020-22 (Income Tax); Rev. Rul. 2020-24 (Income Tax); TD 9911 (Income Tax); TD 9913 (Income Tax); TD 9918 (Income Tax).

October 30, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup October 19 – October 23, 2020

by McDermott Will & Emery | Oct 27, 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 October 19, 2020 – October 23, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 20, 2020: The IRS released Announcement 20-40 regarding the effective date of the termination of the shipping agreement between the United States and Hong Kong.

October 22, 2020: The IRS released Draft Instructions to Form 1065, which include revised instructions for partnerships required to report capital accounts to partners on Schedule K-1 (Form 1065).

October 23, 2020: The IRS released a statement notifying taxpayers that the IRS will resume issuing 500 series balance due notices.

October 23, 2020: The IRS released Internal Revenue Bulletin 2020-44, dated October 26, 2020, containing the following highlights: TD 9924 (Employment Tax) and TD 9910 (Income Tax).

October 23, 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 October 12 – October 16, 2020

by McDermott Will & Emery | Oct 19, 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 October 12, 2020 – October 16, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 13, 2020: The IRS published final regulations related to the absorption of consolidated net operating loss (CNOL) carryovers and carrybacks, as well as consolidated groups that include both life insurance companies and other companies.

October 14, 2020: The IRS released a draft of instructions for Form 5472 related to an information return of a 25% foreign-owned US corporation or a foreign corporation engaged in a US trade or business.

October 16, 2020: The IRS published Revenue Ruling 2020-22 updating the applicable federal rate (AFR) for November 2020.

October 16, 2020: The IRS published Notice 2020-47 updating the weighted average interest rate, the yield curve and segment rates used by certain benefit plans.

October 16, 2020: The IRS published Revenue Procedure 2020-46, which adds that a distribution to a state unclaimed property fund is a permissible reason to self-certify eligibility for a waiver to the 60-day rollover requirement for qualified plans and individual retirement arrangements.

October 16, 2020: The IRS published Revenue Procedure 2020-43 providing the maximum amount that may be made newly available for the plan year for an excepted benefit health reimbursement arrangement.

October 16, 2020: The IRS released Internal Revenue Bulletin 2020-43, dated October 19, 2020, containing the following highlights: Notice 2020-70 (Administrative) and TD 9920 (Employment Tax).

October 16, 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 October 5 – October 9, 2020

by McDermott Will & Emery | Oct 14, 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 October 5, 2020 – October 9, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 7, 2020: The IRS published final regulations related to the withholding tax and information reporting requirements for the sale, exchange or redemption of a partnership interest held by a foreign person.

October 7, 2020: The IRS published a draft of Publication 509 with draft tax calendars for 2021.

October 9, 2020: The IRS published Revenue Ruling 2020-19 related to changes in basis of computing life insurance reserves.

October 9, 2020: The IRS published Revenue Procedure 2020-44 to facilitate a transition from interbank offered rates to alternate reference rates.

October 9, 2020: The IRS released Internal Revenue Bulletin 2020-42, dated October 13, 2020, containing the following highlights: REG-110059-20 (Income Tax); TD 9908 (Income Tax).

October 9, 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 September 28 – October 2, 2020

by McDermott Will & Emery | Oct 7, 2020 | IRS Guidance, Settlements, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 29, 2020: The IRS published final regulations related to the source of income for certain property sales and modifying rules for determining whether foreign source income is effectively connected with a US trade or business.

September 29, 2020: The IRS published final regulations related to a wide range of foreign tax credit topics. The regulations provide guidance on the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments and the treatment of certain payments under the global intangible low-taxed income provisions.

October 1, 2020: The IRS published Notice 2020-70 generally removing Form 1040NR, US Nonresident Alien Income Tax Return, from the list of returns that are administratively exempt from the electronic filing requirement.

October 1, 2020: The IRS published final regulations related to savings programs for eligible individuals with a disability under section 529A.

October 1, 2020: The IRS released an Office of Chief Counsel Notice related to settlement options for syndicated conservation easement transactions.

October 2, 2020: The IRS published Notice 2020-76 providing for transition relief related to information reporting requirements related to the Affordable Care Act.

October 2, 2020: The IRS updated the instructions for Form 8858: Information Return of US Persons with Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs) to reflect changes due to the COVID-19 pandemic.

October 2, 2020: The IRS released Internal Revenue Bulletin 2020-41, dated October 5, 2020, containing the following highlights: Announcement 2020-12 (Administrative); Rev. Proc. 2020-42 (Administrative); Rev. Rul. 2020-20 (Income Tax); Rev. Rul. 2020-21 (Income Tax); TD 9915 (Income Tax); Notice 2020-73 (Income Tax); Notice 2020-74 (Income Tax).

September 25, 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 September 21 – September 25, 2020

by McDermott Will & Emery | Oct 2, 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 September 21, 2020 – September 25, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 21, 2020: The IRS released Announcement 2020-12 to detail information reporting requirements for taxpayers seeking forgiveness of Paycheck Protection Program loans under the Coronavirus Aid, Relief and Economic Security (CARES) Act.

September 21, 2020: The IRS published final regulations related to bonus depreciation. The rules provide additional guidance to final regulations issued in 2019.

September 21, 2020: The IRS published final regulations providing guidance for certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a trade or business within the United States.

September 21, 2020: The IRS published final regulations clarifying that certain deductions allowed to an estate or non-grantor trust are not miscellaneous non-itemized deductions.

September 22, 2020: The IRS issued proposed regulations to modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under section 367(a) and narrow the scope of foreign corporations that are treated as controlled foreign corporations for purposes of the look-through rule under section 954(c)(6).

September 22, 2020: The IRS published final regulations related to the downward attribution for ownership determination of controlled foreign corporations (CFCs) following changes in the Tax Cuts and Jobs Act.

September 24, 2020: The IRS announced that it will provide tax relief for victims of Hurricane Sally by extending the deadline for filing and payment deadlines that would have been due October 15, 2020, until January 15, 2021.

September 25, 2020: The IRS updated the instructions for Form 8858: Information Return of US Persons with Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs) to reflect changes due to the COVID-19 pandemic.

September 25, 2020: The IRS released Internal Revenue Bulletin 2020-40, dated September 28, 2020, containing the following highlights: Notice 2020-66 (Administrative); Announcement 2020-17 (Employee Plans Administrative); Notice 2020-72 (Employee Plans); Notice 2020-59 (Income Tax); Notice 2020-71 (Income Tax); REG-107911-18 (Income Tax); Rev. Proc. 2020-41 (Income Tax); Rev. Rul. 2020-19 (Income Tax); TD 9905 (Income Tax).

September 25, 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 September 14 – September 18, 2020

by McDermott Will & Emery | Sep 22, 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 September 14, 2020 – September 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 14, 2020: The IRS published final regulations providing guidance on the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the Tax Cuts and Jobs Act (TCJA) and the Coronavirus Aid, Relief and Economic Security Act (CARES Act). The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation and how the limitation applies in consolidated group, partnership, international and other contexts. The final regulations vary slightly from the document released on IRS.gov on July 28, 2020.

September 14, 2020: The IRS published a criminal tax bulletin concerning recent case law involving the Criminal Tax Division.

September 15, 2020: The IRS published Rev. Rul. 2020-20 that provides various prescribed rates for federal income tax purposes for October 2020, including: (1) the applicable federal rates (AFR) under section 1274(d); (2) the adjusted applicable federal rates (adjusted AFR) under section 1288(b); (3) the adjusted federal long-term rate and the long-term tax-exempt rate under section 382(f); (4) the appropriate percentages for determining the low-income housing credit under Section 42(b)(1); and (5) the federal rate for determining the present value of an annuity, an interest for life or for a term of years or a remainder or a reversionary interest under section 7520.

September 15, 2020: The IRS published a practice unit covering Last In-First Out (LIFO) inventories under various LIFO methods.

September 15, 2020: The IRS released for future publication in the Federal Register final regulations concerning the definition of an eligible terminated S corporation and rules relating to distributions of money by such a corporation after the post-termination transition period. The regulation package also amends current regulations to extend the treatment of distributions of money during the post-termination transition period to all shareholders of the corporation and clarifies the allocation of current earnings and profits to distributions of money and other property. The final regulations affect C corporations that were formerly S corporations and the shareholders of such corporations.

September 16, 2020: The IRS published a memorandum providing flexibility for taxpayers who are temporarily unable to meet the payment terms on accepted offers due to the economic impact of COVID-19. The procedures will expire December 31, 2020, unless extended.

September 17, 2020: The IRS published a practice unit providing an overview of the Overall Foreign Loss (OFL), Separate Limitation Loss (SLL) and Overall Domestic Loss (ODL) rules, as well as related examples.

September 17, 2020: The IRS
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Are Crypto Loans Taxed as Loans?

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

Transactions involving the borrowing and lending of units of virtual currency (or crypto loans) are increasing in number and type. Lacking Treasury or IRS guidance with respect to crypto loans, potential tax issues that arise from these transactions must be analyzed and understood in accordance with broad, general tax principles established by case law and based on government guidance developed in other tax areas.

Access the full article here.

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