Section 301 Archives - TAX CONTROVERSY 360

Weekly IRS Roundup May 6 – 10, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019.

May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue Procedure 75-50 in order to reflect technological advances. Revenue Procedure 75-50 provides guidelines to determine whether a private school has adopted racially nondiscriminatory policies for tax exemption purposes.

May 7, 2019: The IRS released Notice 2019-33 requesting comments regarding possible normalization issues stemming from the decrease in the corporate tax rate under Section 11 of the Code.

May 7, 2019: The IRS issued a news release recognizing National Small Business Week and reminding taxpayers that a tax identification number will now be required when requesting an employer identification number.

May 8, 2019: The IRS released Notice 2019-34 providing the inflation-adjusted maximum value of employer provided vehicles first made available to employees for personal use in 2019.

May 9, 2019: The IRS released Revenue Ruling 2019-13 ruling that if a former S corporation makes a Section 301 cash distribution during its post termination period it should reduce its accumulated adjustments account to the extent of the proceeds of the redemption.

May 9, 2019: The IRS issued a news release highlighting tax reform changes that impact depreciation and expensing for businesses as part of a series of news releases during National Small Business Week.

May 10, 2019: The IRS released final regulations providing guidance regarding qualified business units subject to Section 987 of the Code and withdrawing foreign currency partnership allocation rules.

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

Weekly IRS Roundup March 25 – 29, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25 – 29, 2019.

March 25, 2019: The IRS issued Proposed Regulations under Section 301 of the code updating existing regulations to reflect changes made by the Technical and Miscellaneous Revenue Act of 1988.

March 25, 2019: The IRS issued Proposed Regulations partially withdrawing and re-proposing 2016 proposed regulations addressing transactions where property of a corporation becomes property of a real estate investment trust (REIT) following certain corporate distributions of controlled corporation stock.

March 26, 2019: The IRS issued Notice 2019-22 announcing the phase out of the Section 30D plug-in electric drive motor vehicle credit for purchasers of eligible General Motors’ vehicles beginning April 1, 2019.

March 27, 2019: The IRS issued Announcement 2019-03 providing an annual report on advance pricing agreements and the Advance Pricing and Mutual Agreement Program.

March 28, 2019: The IRS withdrew proposed regulations (REG-143686-07) that provided guidance on the allocation and recovery of basis in corporate stock redemptions under Section 301 of the code.

March 28, 2019: The IRS issued Revenue Procedure 2019-15 providing a waiver from time requirements for individuals electing to exclude their foreign earned income who must leave a country due to war, civil unrest or similar circumstances.

March 28, 2019: The IRS issued Notice 2019-24 providing adjustments to the limitation on housing expenses under Section 911 of the code.

March 29, 2019: The IRS issued Revenue Ruling 2019-11 providing guidance to taxpayers regarding the inclusion in income of recovered state and local taxes in the current year when the taxpayer deducted state and local taxes paid in a prior year.

March 29, 2019: The IRS withdrew proposed regulations (REG-124627-11) that provided guidance on the continuity of interest requirement under Section 368 of the code.

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