Form 3800 Archives - TAX CONTROVERSY 360

Weekly IRS Roundup August 3, 2020 – August 7, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 3, 2020 – August 7, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 3, 2020: The IRS published a news release announcing that James Lee will become the new chief of IRS Criminal Investigation on October 1, 2020.

August 4, 2020: The IRS published a notice and request for comments concerning Form 3800 (General Business Credit), which is the form taxpayers file to claim any of the general business credits. Comments are due on or before October 5, 2020.

August 4, 2020: The IRS published corrections to final regulations under Treasury Decision 9896 that were published in the Federal Register on Wednesday, April 8, 2020. The final regulations provide guidance regarding hybrid dividends and certain amounts paid or accrued pursuant to hybrid arrangements, which generally involve arrangements whereby US and foreign tax law classify a transaction or entity differently for tax purposes. The corrections are effective on August 4, 2020.

August 4, 2020: The IRS added new content to Internal Revenue Manual 21.7.2 concerning a new major subsection with COVID-19 related employment tax relief guidance.

August 5, 2020: The IRS released public comments in response to Notice 2020-43, which requested comments on a proposed requirement for partnerships to use only one of two alternative methods (described in the notice) to satisfy the tax capital reporting requirement with respect to partnership taxable years that end on or after December 31, 2020. If adopted, partnerships and certain other persons would no longer be permitted to report partner capital accounts using any other method, including section 704(b) and US generally accepted accounting principles.

August 7, 2020: The IRS released Internal Revenue Bulletin 2020-33, dated August 10, 2020, containing the following: Announcement 2020-10, Announcement 2020-11; Revenue Procedure 2020-37; T.D. 9901, T.D. 9902; REG-127732-19.

August 7, 2020: The IRS announced corrections to Treasury Decision 9900, published in Internal Revenue Bulletin 2020-30 on Monday, July 20, 2020, regarding consolidated net operating loss deductions. The corrections revise the applicability date of the temporary regulations, revise the amended return filing date, and revise a specific regulation’s expiration date.

August 7, 2020: The IRS released for publication in the Federal Register final regulations under sections 162, 164, and 170 affecting taxpayers who make transfers to entities described in section 170(c) for business purposes and taxpayers who receive state or local tax credits in exchange for transfers to such entities or who receive other third party benefits in exchange for transfers to such entities. The final regulations: (1) update the regulations under section 162 to reflect current law regarding the application of section 162 to taxpayers that make payments or transfers for business purposes to entities described in section 170(c); (2) provide safe harbors under section 162 to provide certainty with respect to the treatment of payments made by business [...]

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Weekly IRS Roundup July 20 – July 24, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 20, 2020 – July 24, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 20, 2020: The IRS published a news release on after-tax-day tips for taxpayers who missed the July 15, 2020, tax deadline and did not request an extension. The tips include advice on obtaining a refund and on reducing penalties and interest.

July 20, 2020: The IRS released public comments on the 2020-21 Priority Guidance Plan in response to Notice 2020-47, which invited the public to submit recommendations for items to be included on the 2020-2021 Priority Guidance Plan. The US Department of the Treasury and the IRS use the Priority Guidance Plan each year to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.

July 21, 2020: The IRS announced the creation of the new Enterprise Digitalization and Case Management office, which will spearhead IRS efforts to empower taxpayers and IRS employees to rapidly resolve issues in a simplified digital environment. The office’s efforts will support overall IRS modernization and implementation of long-term changes stemming from the Taxpayer First Act. The new stand-alone office will focus on enhancing the taxpayer experience by improving business processes and modernizing systems.

July 22, 2020: The IRS published a notice to solicit comments on Form 3800 (General Business Credit). Section 38 permits taxpayers to reduce their income tax liability by the amount of their general business credit, which is an aggregation of various credits. Form 3800 is used to figure the correct credit. Comments are due on or before September 21, 2020.

July 23, 2020: The IRS published a notice requesting comments on TD 8435 that provides final income, estate and gift, and employment tax regulations relating to elections made under the Technical and Miscellaneous Revenue Act of 1988. This regulation enables taxpayers to take advantage of various benefits provided by the Internal Revenue Code (Code). Comments are due on or before September 21, 2020.

July 23, 2020: The IRS published final regulations under the global intangible low-taxed income (GILTI) and subpart F income provisions of the Code regarding income subject to a high rate of foreign tax. The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their GILTI computation on an elective basis. The final regulations are effective on September 21, 2020.

July 23, 2020: The IRS also published proposed regulations that generally conform the rules implementing the subpart F high-tax exception to the rules implementing the GILTI high-tax exclusion set forth in the final regulations, and provided for a single election under section 954(b)(4) for purposes [...]

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Weekly IRS Roundup August 3, 2020 – August 7, 2020

Weekly IRS Roundup July 20 – July 24, 2020

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