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written determinations

Weekly IRS Roundup November 29 – December 3, 2021

by McDermott Will & Emery | Dec 6, 2021 | Appellate Courts, IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 29, 2021 – December 3, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 29, 2021: The IRS published a news release warning taxpayers and tax professionals to beware of a dangerous combination of events that can increase their exposure to tax scams and identity theft. The IRS stated that the holiday shopping season, the upcoming tax season and the pandemic all create additional opportunities for criminals to steal sensitive personal or finance information.

November 30, 2021: The IRS issued Revenue Procedure 2021-53, which provides temporary guidance regarding the treatment of certain stock distributions by publicly offered real estate investment trusts and publicly offered regulated investment companies in recognition of the need for liquidity as a result of COVID-19. The guidance reduces the minimum required aggregate amount of cash that distributee shareholders may receive to no less than 10% of the total distribution in order for Section 301 (by reason of Section 305(b)) to apply to such distribution.

November 30, 2021: The IRS published a news release warning taxpayers to be wary of fake charities used by scammers to trick unsuspecting donors into providing money and sensitive financial and personal information.

November 30, 2021: The IRS posted an issue snapshot concerning issue indicators and audit tips for public and tax-exempt employer contributions to eligible deferred compensation plans (as defined in Section 457(b)).

December 1, 2021: The US Competent Authority posted the arrangement between Competent Authorities of the United States and Turkey, setting forth parameters on the exchange of county-by-country reporting agreements to combat transfer pricing, base erosion and profit shifting-related risks.

December 1, 2021: The IRS published a news release reminding taxpayers they can get extra protection starting in January by joining its Identity Protection Personal Identification Number (IP PIN) program. Anyone who can verify their identity can protect themselves against tax-related identity theft by opting into the program.

December 2, 2021: The IRS published a news release warning tax professionals that they face additional security risks from cybercriminals seeking to use the pandemic and phishing scams to steal sensitive client information.

December 2, 2021: The IRS recommended nonacquiescence in Mayo Clinic v. United States, 997 F.3d 789 (8th Cir. May 13, 2021), rev’g 412 F. Supp. 3d 1038 (D. Minn. 2019), where the appeals court invalidated Treasury Regulations Section 1.170A-9(c)(1)’s requirement that the primary function of an educational organization described in Section 170(b)(1)(A)(ii) be the presentation of formal instruction. For more background, see our recent post.

December 2, 2021: The IRS published a news release reminding tax professionals and taxpayers that they can use digital signatures on a variety of common IRS forms and access a [...]

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Weekly IRS Roundup November 22 – November 26, 2021

by McDermott Will & Emery | Nov 29, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 22, 2021 – November 26, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 22, 2021: The IRS released a memorandum concerning a temporary deviation from the handwritten signature requirement for certain tax forms. To alleviate COVID-19 concerns while promoting timely filing, the IRS will allow taxpayers and representatives to use electronic or digital signatures when signing listed forms that currently require a handwritten signature. No specific technology is required to create the signature. The IRS has listed the eligible forms, which must be postmarked on August 28, 2020, or later.

November 22, 2021: The IRS released a memorandum extending through October 31, 2023, temporary deviations that allow IRS employees to: (1) accept images of signatures and digital signatures on documents related to the determination or collection of tax liability and (2) send or receive documents to or from taxpayers using emails with encrypted attachments when no other approved electronic alternative is available.

November 22, 2021: The IRS released a memorandum providing guidance concerning employee retention credits and the deferral of paying social security taxes in 2020.

November 23, 2021: The IRS published a news release announcing the launch of a new Spanish-language version of the Child Tax Credit Update Portal (CTC-UP). Families who are already receiving monthly payments use the CTC-UP to update their accounts. Now, all the features that have only been available in English are also available in Spanish.

November 26, 2021: The IRS published a notice and request for comments on Form 944, Employer’s Annual Employment Tax Return, and Form 944-X, Adjusted Employer’s Annual Federal Tax Return or Claim for Refund, which are used in part to ensure the smallest non-agricultural and non-household employers are paying the correct amount of social security tax, Medicare tax and withheld federal income tax. Comments are due on or before January 25, 2022.

November 26, 2021: The IRS published a notice and request for comments concerning TD 8857 (addressing the determination of underwriting income by non-life insurance companies), which allows a non-life insurance company to increase unpaid losses on a yearly basis by the amount of estimated salvage recoverable if the company discloses this to the state insurance regulatory authority. Comments are due on or before January 28, 2022.

November 26, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Robbie Alipour in our Chicago office for this week’s roundup.

Weekly IRS Roundup November 15 – November 19, 2021

by McDermott Will & Emery | Nov 24, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 15, 2021 – November 19, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 15, 2021: The IRS published a news release announcing the launch of a new online tool designed to help US withholding agents comply with their reporting and withholding responsibilities with respect to IRS Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding. The tool performs a quality review of data before submitting to the IRS. Use of the tool does not change a withholding agent’s obligations to file Form 1042-S with the IRS and furnish a copy to the payee.

November 15, 2021: The IRS published a news release announcing that victims of wildfires that began July 14, 2021, now have until January 3, 2022, to file various individual and business tax returns and make tax payments.

November 16, 2021: The IRS published a news release announcing that, effective November 15, 2021, tax professionals are able to order up to 30 Transcript Delivery System transcripts per client through the Practitioner Priority Service line. This is an increase from the previous 10 transcripts per client limit.

November 16, 2021: The IRS published a news release regarding Notice 2021-63, which details how the temporary 100% business deduction for food or beverages from restaurants applies to taxpayers properly applying the rules of Revenue Procedure 2019-48 when using per diem rates.

November 17, 2021: The IRS published a news release announcing that victims of Hurricane Ida throughout Mississippi now have additional time—until January 3, 2022—to file various individual and business tax returns and make tax payments.

November 17, 2021: The Internal Revenue Service Advisory Council (IRSAC) published a news release announcing its annual report for 2021, which includes recommendations to the IRS regarding new and continuing issues in tax administration. The 2021 report includes recommendations on 24 issues, covering a broad range of topics. The IRSAC is a federal advisory committee that provides an organized public forum for the discussion of relevant tax administration issues between IRS officials and representatives of the public. IRSAC members offer constructive observations regarding current or proposed IRS policies, programs and procedures.

November 17, 2021: The IRS published a news release announcing it unveiled a new how-to video series enabling taxpayers to avoid potential scams by considering and applying for an Offer in Compromise themselves and to avoid paying excessive fees to companies advertising outlandish claims.

November 17, 2021: The IRS published a news release announcing the launch of an improved identity verification and sign-in process that enables more people to securely access IRS online tools and applications.

November 17, 2021: The IRS’s National Taxpayer Advocate published a blog post indicating that US Congress [...]

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Weekly IRS Roundup November 8 – November 12, 2021

by McDermott Will & Emery | Nov 17, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 8, 2021 – November 12, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 9, 2021: The IRS released a Treasury Decision, requesting written comments on T.D. 9360, which provides guidance regarding the information a taxpayer must provide in order to substantiate its computation of its share of a passive foreign investment company (PFIC) post-1986 earning and profits. Written comments must be received before January 10, 2022.

November 9, 2021: The IRS released draft instructions for Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI). Under these instructions, taxpayers must attach either a separate Schedule A or a separate Schedule B, depending upon whether the entity’s US shareholder is a taxpayer of a US consolidated group. In addition, domestic partnerships are no longer required to fill out Form 8892. Instead, they must now complete Schedules K-2 and K-3 on Form 1065.

November 10, 2021: The IRS issued a news release and a revenue procedure, announcing the tax year 2022 annual inflation adjustments. These adjustments affect more than 60 tax provisions, including the tax rate schedules, and will be used for tax returns filed in 2023.

November 10, 2021: The IRS issued the 2021 IRS Financial Report, which provides a comprehensive view of the IRS’s financial activities and its finance management community. The report specifies, among other items, the tax revenue managed by the IRS, the amount of refunds it has issued and the amount of unpaid assessments.

November 11, 2021: The IRS released a revenue procedure, requesting comments on Revenue Procedure 2008-60, which affects taxpayers who are maintaining a surety bond or a Treasury Direct Account to satisfy the low-income housing tax credit recapture exception in Section 42(j)(6). Written comments must be received before January 14, 2022.

November 12, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Jennifer Saperstein in our Chicago office for this week’s roundup.

Weekly IRS Roundup November 1 – November 5, 2021

by McDermott Will & Emery | Nov 8, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 1, 2021 – November 5, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 1, 2021: The IRS released a memorandum, providing guidance on the refund recoupment process for employees of Specialty Collection Offer in Compromise. Beginning with offers accepted on or after November 1, 2021, the offer in the compromise refund recoupment process will no longer be applicable for offsetting tax periods included on Form 656.

November 1, 2021: The IRS released a memorandum, extending certain temporary guidance related to taxpayer contact, initial contact and asset evaluations with respect to Internal Revenue Manual SBSE-05-0321-0019, Extension of Temporary Guidance for Field Collection and Specialty Collection Offers in Compromise Procedures During the COVID-19 Pandemic and Resumption of NFTL Procedures. The memorandum also extends the waiver that requires a field call prior to acceptance of certain Offers in Compromise in accordance with IRM 5.8.4.8(10) until January 31, 2022. The temporary guidance regarding Notice of Federal Tax Lien (NFTL) determinations and filings was not extended.

November 2, 2021: The IRS released the IRS Chief Counsel code and subject matter directory for November 2021.

November 3, 2021: The IRS published a news release, reminding taxpayers that a special tax provision will allow more Americans to easily deduct up to $600 in donations to qualifying charities on their 2021 federal income tax return. A temporary law change now permits them to claim a limited deduction on their 2021 federal income tax returns for cash contributions made to qualifying charitable organizations.

November 3, 2021: The IRS published FAQs concerning carried interest reporting details for partnerships. The purpose of the FAQs is to provide guidance relating to both pass-through entity filing and reporting requirements and owner taxpayer filing requirements in accordance with US Department of the Treasury (Treasury) regulations revised in T.D. 9945 (concerning guidance under Section 1061, which recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains).

November 3, 2021: The IRS published a news release, announcing that victims of Hurricane Ida in parts of Connecticut now have until January 3, 2022, to file various individual and business tax returns and make tax payments.

November 3, 2021: The IRS and Treasury published a notice and request for comments concerning third-party disclosure requirements in IRS regulations. Written comments are due on or before January 3, 2022.

November 5, 2021: The IRS published a practice unit concerning expense allocation and apportionment when calculating a foreign tax credit under Section 904. The practice unit was revised to correct an error and supersedes the August 29, 2016, practice unit with the same title.

November 5, 2021: The IRS and Treasury
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Weekly IRS Roundup October 25 – October 29, 2021

by McDermott Will & Emery | Nov 1, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 25, 2021 – October 29, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 25, 2021: The IRS released a memorandum implementing the Large Partnership Compliance (LPC) Pilot Program, including the identification, selection and delivery of large partnership tax returns, exam procedures and feedback.

October 25, 2021: The IRS released a memorandum providing emergency guidance on emails with personal accounts in exigent circumstances to IRS employees responsible for protecting sensitive but unclassified data, including tax information and personally identifiable information.

October 26, 2021: The IRS and US Department of the Treasury (Treasury) published a notice and request for comments concerning the foreign tax credit used by individuals, estates or trusts. Comments are requested on Form 1116, Foreign Tax Credit (Individual, Estate or Trust), and Schedules B and C, which are used by individuals (including nonresident aliens), estates or trusts who paid foreign income taxes on US taxable income to compute the foreign tax credit. Written comments are due on or before December 27, 2021.

October 26, 2021: The IRS published a practice unit examining education expenses claimed by Nonresident Alien Individual (NRA) employees. The unit focuses on examining the education expenses claimed by NRAs engaged in a US trade or business as employees and discusses the issues and audit steps that examiners will need to consider for these taxpayers.

October 27, 2021: The IRS published a new release announcing that victims of Hurricane Ida in parts of Mississippi now have additional time—until January 3, 2022—to file various individual and business tax returns and make tax payments. The deadline remains November 1, 2021, for affected taxpayers in other parts of Mississippi.

October 28, 2021: The IRS and Treasury published a notice and request for comments concerning Form 3468 (Investment Credit). The form is used to compute taxpayers’ credit against their income tax for certain expenses incurred for their trades or businesses. Written comments are due on or before December 27, 2021.

October 29, 2021: The IRS and Treasury published a notice and request for comments concerning Form SS-4 (Application for Employer Identification Number). The form is used by taxpayers who are required to have an identification number for use on any return, statement or other document to obtain such number. Written comments are due on or before December 28, 2021.

October 29, 2021: The IRS and Treasury published a notice and request for comments concerning rules relating to the manner and method of reporting and paying the nondeductible 50% excise tax imposed by Section 5881 with respect to the receipt of greenmail. Written comments are due on or before December 28, 2021.

October 29, 2021: The IRS released a memorandum [...]

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Weekly IRS Roundup October 18 – October 22, 2021

by McDermott Will & Emery | Oct 27, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 18, 2021 – October 22, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 18, 2021: The IRS announced that beginning October 18, its Large Business and International (LB&I) Division will accept all taxpayer requests to meet with IRS employees using secure video conferencing.

October 20, 2021: The IRS published an announcement, reminding employers that the next quarterly payroll tax return is due November 1, 2021. The IRS urged employers to use the speed and convenience of filing the returns electronically.

October 21, 2021: The IRS and US Department of the Treasury (Treasury) published a notice and request for comments concerning Form 4810 (Request for Prompt Assessment Under Internal Revenue Code Section 6501(d)). The form is used to help locate a return and expedite the processing of a taxpayer’s request. Written comments are due on or before December 20, 2021.

October 21, 2021: The IRS published an announcement, reminding the more than 759,000 federal tax return preparers that they must renew their Preparer Tax Identification Numbers (PTINs) now for 2022. All current PTINs will expire December 31, 2021.

October 21, 2021: The IRS published a notice, setting forth current standards that a limited liability company (LLC) must satisfy in order to receive a determination letter recognizing it as tax exempt under Section 501(a) and described in Section 501(c)(3). The notice also requests comments on these standards, as well as specific issues relating to tax exempt status for LLCs, to assist the Treasury and the IRS in determining whether additional guidance is needed concerning the standards that an LLC must satisfy in order to be exempt from taxation by reason of being described in Section 501(c). Written comments should be submitted by February 6, 2022.

October 22, 2021: The IRS published an announcement, reminding employers that they generally will not jeopardize the tax status of their pension plans if they rehire retirees or permit distributions of retirement benefits to current employees who have reached age 59 and a half or the plan’s normal retirement age. The IRS posted FAQs to help employers impacted by COVID-19, which resulted in labor shortages.

October 22, 2021: The IRS published Revenue Procedure 2021-42, providing guidelines and general requirements for the development, printing and approval of the 2021 substitute tax forms. The IRS accepts quality substitute tax forms that are consistent with the official forms and have no adverse impact on processing.

October 22, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Robbie Alipour in our Chicago office for this week’s roundup.

Weekly IRS Roundup October 11 – October 15, 2021

by McDermott Will & Emery | Oct 18, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 11, 2021 – October 15, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 12, 2021: The IRS released a notice, announcing that the US Department of the Treasury (Treasury) and the IRS intend to amend the regulations under Section 987 to defer the applicability date of certain final regulations by one additional year. The deferred regulations will apply to tax years beginning after December 7, 2022. For calendar year taxpayers, the 2016 final regulations and the related 2019 final regulations will apply to the tax year beginning on January 1, 2023. The IRS and Treasury do not intend to amend the applicability date of Treasury Regulation § 1.987-12.

October 13, 2021: The IRS published an updated Form W-8BEN-E (Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities)) and related instructions.

October 14, 2021: The IRS and Treasury published a notice and request for comments concerning assumption of partner liabilities. The rules relate to a partnership’s assumption of certain fixed and contingent obligations in connection with the issuance of a partnership interest, as well as to Section 358(h) for assumptions of liabilities by corporations from partners and partnerships and temporary regulations concerning the assumption of certain liabilities under Section 358(h). Written comments are due on or before December 13, 2021.

October 14, 2021: The IRS and Treasury published a notice and request for comments concerning Form 1127 (Application for Extension of Time for Payment of Tax Due to Undue Hardship). Written comments are due on or before December 13, 2021.

October 14, 2021: The IRS and Treasury published a notice and request for comments concerning Revenue Procedure 99-50, which permits combined information reporting by a successor business entity (i.e., a corporation, partnership or sole proprietorship) in certain situations following a merger or an acquisition. Written comments are due on or before December 13, 2021.

October 15, 2021: The IRS published draft instructions for Form 8949 (Sales and Other Dispositions of Capital Assets). The updated form reflects reporting for Section 1061, which concerns recharacterizing certain long-term capital gains of a partner who holds one or more applicable partnership interests as short-term capital gains.

October 15, 2021: The IRS published a news release, updating its process for certain frequently asked questions (FAQs) on newly-enacted tax legislation. The IRS is updating this process to address concerns regarding transparency and the potential impact on taxpayers when the FAQs are updated or revised. The IRS is also addressing concerns regarding the potential application of penalties to taxpayers who rely on FAQs by providing clarity as to their ability to rely on FAQs for penalty protection. The IRS stated that significant FAQs on newly-enacted [...]

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Weekly IRS Roundup October 4 – October 8, 2021

by McDermott Will & Emery | Oct 11, 2021 | IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 4, 2021 – October 8, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 4, 2021: The IRS released a practice unit, providing tax law and audit steps for reviewing a reseller’s uniform capitalization cost computations under section 263A. The practice unit focuses on the simplified production method and does not cover the final section 263A Treasury Regulations that were effective November 20, 2018.

October 4, 2021: The IRS published a news release, announcing 18 self-study seminars available online through the IRS Nationwide Tax Forums. The seminars cover topics such as the gig economy and virtual currency.

October 4, 2021: The IRS published instructions for Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting (Individuals)) concerning:

Guidance under section 1446(f) (withholding on partnership interest dispositions)
New lines 6a and 6b (addressing foreign tax ID number (FTIN) matters)
Tax treaty benefits claims (requiring representations)
Section 6050Y reporting (covering life insurance contracts and reportable death benefits)
Electronic signatures (updated to reflect new guidance)

October 5, 2021: The IRS published a news release, announcing that Free File remains available through October 15 for taxpayers who still need to file their 2020 tax returns. Free File is the IRS’s public-private partnership with tax preparation software industry leaders to provide their brand name products for free.

October 5, 2021: The IRS released a memorandum, expanding the criteria for collection due process cases that qualify for a rapid response appeals process under IRM 8.22.6.2 and related subsections.

October 5, 2021: The IRS released a memorandum concerning interim guidance regarding the IRS Independent Office of Appeals’ steps and procedures for its nationwide pilot program: The Appeals Electronic Case Files Initiative for Large Business & International (LB&I) report generation software (RGS) examination cases. This guidance is applicable to LB&I RGS International Individual Compliance cases only and excludes other large cases such as Tax Equity and Fiscal Responsibility Act of 1982 cases, Bipartisan Budget Act of 2015 cases and Syndicated Conservation Easement cases.

October 5, 2021: The IRS released a memorandum updating procedures where an organization requests a change in a section 501 subsection during the application process by submitting one application form to replace a different application form. The procedures are effective 30 days after issuance of the memorandum and supersedes those in TEGE-07-0421-0010 (April 29, 2021).

October 7, 2021: The IRS published a program letter indicating that, in Fiscal Year 2022, Tax Exempt (TE)/Government Entities (GE) commissioners expect to invest in new resources to expand outreach to the exempt sector as well as increase their enforcement staff.

October 8, 2021: The IRS released its weekly list of written [...]

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Weekly IRS Roundup September 27 – October 1, 2021

by McDermott Will & Emery | Oct 4, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 28, 2021: The IRS released a revenue procedure, adding Chile to the list of jurisdictions with which the United States has a relevant information exchange agreement in effect for reporting payments of deposit interest. The IRS also added two countries—the Dominican Republic and Singapore—to the list of jurisdictions with which the US Department of the Treasury (Treasury) and the IRS have determined it is appropriate to have an automatic exchange relationship with.

September 29, 2021: The IRS released draft instructions for supplemental income and loss (Schedule E of Form 1040) concerning the reporting of income or loss from rental real estate, royalties, partnerships, S corporations, estates, trusts and residual interests in real estate mortgage investment conduits (REMICs).

October 1, 2021: The Treasury and the IRS published corrections to final regulations (Treasury Decision 9922) that were published in the Federal Register on November 12, 2020. Treasury Decision 9922 provided guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to consider regarding certain inclusions in income by a US shareholder, conduit financing arrangements involving hybrid instruments and the treatment of certain payments under the global intangible low-taxed income provisions.

October 1, 2021: The Treasury and the IRS published a notice and request for comments concerning all forms used by tax-exempt organizations to determine that such organizations fulfill the operating conditions within the limitations of their tax exemption. The IRS provided a list of the relevant forms. Written comments are due on or before November 30, 2021.

October 1, 2021: The Treasury and the IRS published a notice and request for comments concerning the burden associated with US income tax return forms for individual taxpayers. The request covers Form 1040 and affiliated return forms that are used by individuals to report their income subject to tax and compute their correct tax liability. Written comments are due on or before December 3, 2021.

October 1, 2021: The IRS published a news release reminding US citizens, resident aliens and any domestic legal entity that the extension deadline to file their annual Report of Foreign Bank and Financial Accounts (FBAR) is October 15, 2021.

October 1, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Robbie Alipour in our Chicago office for this week’s roundup.