People First Initiative Archives - TAX CONTROVERSY 360

Weekly IRS Roundup July 6 – July 10, 2020

by McDermott Will & Emery | Jul 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 July 6, 2020 – July 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 6, 2020: The IRS added new frequently asked questions on the treatment of grants or loans to businesses through the Coronavirus Relief Fund established by the Coronavirus Aid, Relief and Economic Security (CARES) Act. The IRS stated that a government grant is taxable because the grant generally is not excluded from the business’s gross income except in narrow circumstances. A government loan, however, generally is not included in gross income except to the extent it is forgiven. If a government forgives all or a portion of the loan, then the amount forgiven is included in gross income and taxable unless an exclusion applies. If an exclusion applies, the IRS indicated the taxpayer may lose an equivalent amount of tax attributes.

July 6, 2020: The IRS added frequently asked questions on the treatment of grants or loans to health care providers through the Provider Relief Fund established by the CARES Act. The IRS stated that payments from this fund do not qualify as a qualified disaster relief payment under section 139 of the Internal Revenue Code (IRC) and, in turn, are includible in gross income. The IRS also stated that a tax-exempt recipient generally is not subject to tax on a fund payment unless the amount is a reimbursement to an unrelated trade or business under section 511.

July 6, 2020: The IRS added content to its Large Business & International (LB&I) Active Campaign covering section 965 for individuals. In connection with the transition to a participation exemption system, certain individuals had an obligation to include in gross income (and report) their pro rata share of the untaxed earnings and profits of certain directly and indirectly owned foreign corporations. The IRS indicated it will address noncompliance through soft letters and examinations.

July 7, 2020: The IRS issued a news release reminding tax-exempt organizations that certain forms they file with the IRS are due on July 15, 2020, including Form 990. Tax-exempt organizations that need additional time to file beyond the July 15 deadline can request an automatic extension by filing Form 8868. The IRS also indicated that extending the time for filing a return does not extend the time for paying tax.

July 8, 2020: The IRS issued a news release reminding certain taxpayers to restart their tax payments by July 15. Some taxpayers took advantage of tax relief measures under the People First Initiative and did not make previously owed tax payments between March 25 and July 15. The IRS also set forth what taxpayers should do to resume their payment agreements to the IRS, including Installment Agreements, Offers in Compromise and [...]

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Weekly IRS Roundup March 23 – 27, 2020

by McDermott Will & Emery | Mar 30, 2020 | Court Procedure Matters, IRS Guidance, Uncategorized

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

March 23, 2020: The US Tax Court cancelled trial sessions from May 4, 2020 through June 29, 2020 due to the COVID-19 outbreak. For further discussion, see here.

March 23, 2020: The IRS updated Publication 946, “How to Depreciate Property”, for use in preparing 2019 tax returns. The updated publication notes the dollar amount in effect for tax IRC Section 179 expensing and the retroactive extension for 2019 and the expiration of certain depreciation at the end of 2020.

March 23, 2020: Final regulations under IRC section 901(m) were released that deal with transactions that generally are treated as asset acquisitions for US income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. These regulations are necessary to provide guidance on applying section 901(m). These regulations affect taxpayers claiming foreign tax credits.

March 24, 2020: The IRS published Questions & Answers (Q&As) regarding the federal income tax filing and payment extension to July 15 to the COVID-19 outbreak. The Q&As provide supplemental information from Notice 2020-18. For further discussion, see here.

March 25, 2020: The IRS announced the “People First Initiative” in response to the COVID-19 outbreak to assist taxpayers in ways such as easing payment guidelines and postponing compliance actions. For further discussion, see here.

March 25, 2020: The IRS released guidance on Forms 8985 and 8986, Part II, Item G, to enter the date the audited partnership originally furnished the Forms 8986 to its partners.

March 27, 2020: The IRS announced Erin M. Collins will be the National Taxpayer Advocate and lead the Taxpayer Advocate Service, an independent organization within the IRS. Collins will start as the National Taxpayer Advocate on March 30, 2020, ahead of the original scheduled start date, due to the COVID-19 outbreak.

March 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 Emily Mussio in our Chicago office for this week’s roundup.

IRS to Temporarily Adjust Operations and Key Compliance Functions

by McDermott Will & Emery and McDermott Will & Emery | Mar 26, 2020 | IRS Guidance, Tax Refunds, Uncategorized

On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges caused by the Coronavirus (COVID-19) pandemic. The initiative’s projected start date is April 1, 2020, and it is planned to continue through at least July 15, 2020. During this period, the IRS will avoid in-person contacts as much as possible while focusing on taking the steps necessary to protect all applicable statutes of limitation.

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