Code Section 267A Archives - TAX CONTROVERSY 360

Weekly IRS Roundup March 18 – 22, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 18 – 22, 2019.

March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on proposed regulations on hybrid arrangements under Sections 245A and 267A of the code.

March 19, 2019: The IRS issued Revenue Procedure 2019-14 providing issuers of qualified mortgage bonds and issuers of mortgage credit certificates the nationwide average purchase price for residences located in the United States, and the average area purchase price safe harbors for residences located in certain statistical areas.

March 20, 2019: The IRS requested comments on the treatment of distributions by foreign corporations and coordination with nonrecognition provisions. Comments should be received by May 20, 2019.

March 20, 2019: The IRS issued a news release announcing the conclusion of what it refers to as the “dirty dozen” list of tax scams.

March 21, 2019: The IRS issued Revenue Ruling 2019-09 suspending two revenue rulings from 1957 pending the completion of a study regarding the active trade or business requirement under Sections 355(a)(1)(C) and (b) of the code.

March 22, 2019: The IRS issued Proposed Regulations on new information reporting requirements for certain life insurance companies under Section 6050Y of the code.

March 22, 2019: The IRS issued Notice 2019-25 modifying and superseding Notice 2019-11. The notice increases the availability of the waiver of the addition to tax for underpayment of estimated income tax for certain individuals for 2018.

March 22, 2019: The IRS issued Notice 2019-26 updating mortality improvement rates and static mortality tables for determining the minimum funding requirements under § 430(h)(3) for 2020. The notice also updates the minimum present value under § 417(e)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2020 calendar year.

Special thanks to Terence McAllister in our New York office for this week’s roundup.

Weekly IRS Roundup November 19 – 23, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 19 – 23, 2018:

November 19, 2018: The IRS in a news release reminds taxpayers that the non-recognition treatment for like-kind exchanges under Code Section 1031 is now limited to certain exchanges of real property.

November 19, 2018: The IRS issued the final regulations under Code Section 267A on allocating costs to certain property produced or acquired for resale by a taxpayer.

November 19, 2018: The IRS issued Revenue Procedure 2018-56, expanding the list of changes of methods of accounting for which the taxpayers may obtain automatic consent under the regulations of Code Section 267A.

November 20, 2018: The IRS issued a notice to request comments on Form W-8CE, Notice of Expatriation and Waiver of Treaty Benefits, which the taxpayers use to notify expatriating payers of information necessary to determine the proper tax treatment of their payments.

November 20, 2018: The IRS in IRS Tax Reform Tax Tip 2018-179 advises that certain taxpayers may benefit from converting an S corporation into a C corporation due to the new, 21 percent tax rate.

November 23, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Alex Cheng-Yi Lee in our DC office for this week’s roundup.