Weekly IRS Roundup December 28, 2020 – January 8, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 29, 2020: The IRS released Revenue Procedure 21-09 providing a procedure for a trade or business that manages or operates a qualified residential living facility to elect to be treated as a real property trade or business for purposes of section 163(j).

December 31, 2020: The IRS issued Notice 21-05 clarifying and modifying the beginning of construction requirement for qualified facility and energy property projects under sections 45 and 48.

December 31, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

December 31, 2020: The IRS released Internal Revenue Bulletin 2021-1, dated January 4, 2021, containing the following highlights: Rev. Proc. 2021-1 (Administrative); Rev. Proc. 2021-2 (Administrative); Rev. Proc. 2021-3 (Administrative); Rev. Proc. 2021-4 (Employee Plans); Rev. Proc. 2021-5 (Exempt Organizations); and Rev. Proc. 2021-7 (Income Tax).

January 4, 2021: The IRS issued Notice 21-07 providing temporary relief for employers and employees using the automobile lease valuation rule due to the COVID-19 pandemic.

January 5, 2021: The IRS issued Revenue Procedure 21-08 modifying Revenue Procedure 2021-5 to provide that the exclusive means of submitting Form 1024-A, after the 90-day transition relief period, is through the electronic submission process.

January 5, 2021: The IRS issued Revenue Procedure 21-10 providing procedures for issuers of tax-advantaged bonds who received adverse determinations by the Office of Tax Exempt Bonds to request an administrative appeal from the Independent Office of Appeals.

January 5, 2021: The IRS released TD 9943 containing the final regulations under section 163(j) related to the limitation on the deduction for business interest expense.

January 6, 2021: The IRS issued Revenue Ruling 21-02 declaring Notice 2020-32 and Rev. Rul. 2020-27, both of which provided that certain taxpayers could not deduct expenses related to loans forgiven under the Paycheck Protection Program, as obsolete.

January 6, 2021: The IRS released TD 9944 containing the final regulations under section 45Q related to the credit for carbon oxide sequestration.

January 7, 2021: The IRS released TD 9945 containing the final regulations under section 1061 related to the characterization of gains for taxpayers directly or indirectly holding applicable partnership interests in connection with the performance of substantial services.

January 8, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 8, 2021: The IRS released Internal Revenue Bulletin 2021-2, dated January 11, 2021, containing the following highlights: TD 9940 (Administrative); Notice 2021-03 (Employee Plans); Notice 2021-04 (Excise Tax); REG-130081-19 (Excise Tax); Notice 2021-01 (Exempt Organizations); Rev. Rul. 2021-01 (Income Tax); and TD 9925 (Income Tax).

Special thanks to Brian Moore in our Washington, DC, office and Samuel DiPietro in our Chicago office for this week’s roundup.



Weekly IRS Roundup December 21 – December 26, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 21 – December 26, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 21, 2020: The IRS released TD 9941 containing final regulations regarding the timing of income inclusion under an accrual method of accounting, including the treatment of advance payments for goods, services and certain other items.

December 22, 2020: The IRS issued Notice 21-02 providing the standard mileage rate for 2021.

December 22, 2020: The IRS issued Notice 21-03 extending temporary relief from the physical presence requirement for spousal consents under certain qualified retirement plans.

December 22, 2020: The IRS issued Notice 21-04 extending temporary relief for certain dyed fuel removals related to the West Shore Pipeline shutdown.

December 23, 2020: The IRS released TD 9942 containing final regulations implementing simplifications to certain tax accounting provisions for certain businesses with annual gross receipts less than $25 million (as adjusted for inflation).

December 24, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

December 26, 2020: The IRS released Internal Revenue Bulletin 2020-53, dated December 28, 2020, containing the following highlights: Rev. Proc. 2020-55 (Administrative); Notice 2020-88 (Administrative, Income Tax); Rev. Proc. 2020-54 (Administrative, Income Tax); Notice 2020-86 (Employee Plans); Notice 2020-87 (Employee Plans); Notice 2020-78 (Income Tax); TD 9921 (Income Tax).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.



Weekly IRS Roundup December 14 – December 18, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 14 – December 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 14, 2020: The IRS released Notice 2020-88 updating and amplifying procedures for Phase III of the section 48A advanced coal credit.

December 16, 2020: The IRS issued Revenue Ruling 21-01 providing various rates for determining the issue price of certain debt instruments issued for property.

December 16, 2020: The IRS issued Notice 21-01 delaying mandatory e-filing of Form 4720 by private foundations and announcing certain other changes.

December 18, 2020: The IRS released TD 9932 containing final regulations under Section 162(m) related to the employer deduction for certain employee remuneration in excess of $1 million.

December 18, 2020: The IRS released Internal Revenue Bulletin 2020-52, dated December 21, 2020, containing the following highlights: Rev. Rul. 2020-81 (Administrative); TD 9912 (Administrative); TD 9933 (Exempt Organizations); TD 9934 (Income Tax); TD 9935 (Income Tax).

December 18, 2020: The IRS released Practice Units on “Determining Liability Allocations” and “Recourse vs. Nonrecourse Liabilities” relating to partnership audits.

December 18, 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 Brian Moore in our Washington, DC, office for this week’s roundup.



Let’s All Stop and Reflect for a Moment

In a recent article for the American Bar Association’s ABA Tax Times, McDermott partner Andrew R. Roberson reflected on 2020 and the importance of giving back.

“From COVID-19 to the Black Lives Matter movement; from home office and Zoom to remote learning for students; and so on—these events have impacted us all, both on professional and personal levels.”

Access the article.



Tax Court Announces New Case Management System to Go Live Before New Year’s

We previously reported on the US Tax Court’s (Tax Court) announcement that it was changing its case management system, DAWSON (Docket Access Within a Secure Online Network). This morning, the Tax Court issued a press release confirming the launch of DAWSON on December 28, 2020. Temporary credentials for taxpayers and practitioners already registered for electronic access will be sent no later than December 28, 2020, and will be valid for seven days. Expanded guidance on using DAWSON, including FAQs, will be available shortly on the Tax Court’s website.



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