Private Letter Rulings Archives - Page 2 of 3

Weekly IRS Roundup September 17 – 21, 2018

by McDermott Will & Emery | Sep 24, 2018 | IRS Guidance, Tax Reform, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 17 – 21, 2018:

September 17, 2018: The Treasury Inspector General for Tax Administration (TIGTA) released a report reviewing whether the IRS complied with legal and internal guidelines governing the seizure of property for unpaid taxes.

September 17, 2018: TIGTA released a second report compiling statistical information reported by the IRS in order to provide information about how the IRS uses its compliance resources and the resulting tax collections.

September 18, 2018: The IRS published Revenue Ruling 2018-17, which provides the applicable federal interest rate for October 2018 and other interest rates.

September 19, 2018: The IRS published Revenue Procedure 2018-49, which allows taxpayers that early adopted a method of revenue recognition to change such method to one described in Section 16.11 of Revenue Procedure 2018-31. This is a very important method change that affects many taxpayers who have to comply with ASC 606.

September 20, 2018: The IRS announced in Notice 2018-72 that it intends to amend the section 871(m) regulations to delay the effective date of certain provisions.

September 21, 2018: Treasury and the IRS published proposed regulations that would remove from the section 385 regulations minimum documentation requirements that must be satisfied for certain related-party debt to be respected as such for tax purposes. We previously commented on this here.

September 21, 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 Kevin Hall in our DC office for this week’s roundup.

Weekly IRS Roundup August 6 – 10, 2018

by McDermott Will & Emery | Aug 13, 2018 | IRS Guidance, Uncategorized

Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 6 – 10, 2018:

August 6, 2018: The IRS and Treasury issued final regulations, which provide guidance regarding the new partnership audit rules. The regulations describe the procedure for designating a partnership representative and the partnership representative’s authority. They also address the time, form and manner of an election to apply the new audit regime to prior partnership tax years.

August 6, 2018: The IRS published Revenue Procedure 2018-40, which describes procedures for small businesses to obtain automatic consent for changing an accounting method to a new method established under the TCJA (P.L. 115-97).

August 7, 2018: The IRS published an updated subject matter directory, available here.

August 8, 2018: The IRS published proposed regulations under new section 199A, which provides a 20 percent deduction for qualifying income earned by certain non-corporate taxpayers during tax years beginning after December 31, 2018. The proposed regulations address which taxpayers are eligible for the deduction and provide guidance regarding the computation of the deduction.

August 8, 2018: The IRS released Notice 2018-64, which includes a proposed revenue procedure that would provide guidance regarding calculating W-2 wages for purposes of the section 199A deduction.

August 10, 2018: The IRS released their weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Kevin Hall in our DC office for this week’s roundup.

Weekly IRS Roundup July 23 – 27, 2018

by McDermott Will & Emery | Jul 31, 2018 | IRS Guidance, Uncategorized

Presented below is our weekly roundup for July 23 – 27, 2018 on significant IRS guidance and relevant tax matters.

July 20, 2018: The IRS has updated its FAQ list for the Foreign Account Tax Compliance Act (FATCA) including new questions and answers regarding the IRS’s updated processing system and certifications for compliance.

July 23, 2018: In Publication 5118, the IRS released the July updated version of the FATCA Online Registration User Guide. This includes, among other additions, changes to enable for financial institutions to submit certifications of pre-existing accounts and periodic certifications.

July 27, 2018: The IRS issued TD 9836 containing final regulations regarding the substantiation and reporting rules for cash and noncash charitable contributions. The regulations provide guidance to individuals, partnerships and corporations.

July 27, 2018: The IRS released their weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Christy Vouri-Misso and Greg Berson in our DC office for this week’s roundup.

Weekly IRS Roundup: June 18 – 22

by McDermott Will & Emery | Jun 25, 2018 | IRS Guidance, Uncategorized

Presented below is our weekly roundup for June 18-22, 2018 on significant IRS guidance and relevant tax matters.

June 18, 2018: The IRS issued Internal Revenue Bulletin No. 2018-25 including: Rev. Rul. 2018-17 (withholding and reporting payments from IRAs to state unclaimed property funds under Internal Revenue Code (Code) Section 3405); and REG-102951-16 (proposing amendments to rules for determining whether information returns must be filed electronically).

June 18, 2018: In IR-2018-139 the IRS stated that people with disabilities can now put more money into their tax-favored ABLE accounts and may, for the first time, qualify for the Saver’s Credit for low- and moderate-income workers.

June 19, 2018: The IRS published Rev. Rul. 2018-19 listing the applicable federal interest rates for July 2018.

June 19, 2018: The IRS proposed regulation REG-131186-17 to reinstate T.D. 9787, including allocations of excess nonrecourse liabilities of a partnership among other changes and removing T.D. 9788.

June 19, 2018: The IRS released a Practice Unit on “Interest Capitalization for Self-Constructed Assets,” which identifies taxpayers subject to Code Section 263A(f) and covers the steps involved in determining how much interest must be capitalized to the basis of designated property.

June 20, 2018: IRS published Rev. Proc. 2018-35 modifying Rev. Proc. 2018-31, to not apply Section 263A to replanting costs for lost or damaged citrus plants pursuant to Code Section 263A(d)(2)(C).

June 21, 2018: The IRS published Notice 2018-48 listing the population census tracts designations by the Treasury for qualified opportunity zones relevant to new Code Section 1400Z-2.

June 22, 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 Christy Vouri-Misso and Greg Berson in our DC office for this week’s round-up.

Yeehaw! McDermott’s Tax Weekly Round Up

by McDermott Will & Emery | Jun 18, 2018 | IRS Guidance, Tax Reform, Uncategorized

Here’s what happened in the world of IRS guidance for the week June 11 – 15, 2018.

June 11, 2018: The IRS issued Notice 2018-55 describing potential proposed regulations that would offer relief to some private colleges and universities by providing a stepped-up basis rule that could reduce the amount of gain subject to a new 1.4 percent excise tax on their endowments.

June 12, 2018: The IRS issued proposed regulations, under Code section 148 applicable to tax-exempt and other tax-advantaged bonds, aimed to restrict arbitrage investments and providing an exception to the definition of investment-type property for capital projects that further the public purpose for which the bonds were issued.

June 12, 2018: Pursuant to its continuing effort to reduce paperwork, the IRS requested comments on a number of published guidance, including: Rev. Proc. 2003-33 (extension of time to file a section 338 election to treat stock purchases as asset acquisitions); TD 8379 and TD 9407 (regulations regarding the manner and method of reporting and paying the excise tax on the receipt of greenmail); TD 8791 (relating to charitable remainder trusts and to special valuation rules for transfers of interests in trusts); and, TD 8571 (relating to the reporting of certain information relating to payments of mortgage interest). All comments are due by August 13, 2018.

June 15, 2018: The IRS announced the corporate bond monthly yield curve, the 24-month average segments rats, the 30-year Treasury securities interest rate, the 30-year Treasury weighted average rate, and the minimum present-value segment rates in Notice 2018-56.

June 15, 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 Christy Vouri and Greg Berson in our DC office for this week’s round-up.