IRS and Treasury Release Update to 2016-2017 Priority Guidance Plan

By and on November 2, 2016

The US Department of the Treasury and Internal Revenue Service (IRS) issue Priority Guidance Plans each year to identify and prioritize the tax issues they believe should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.  On October 31, 2016, the IRS and Treasury released the first quarter update to the 2016-2017 Priority Guidance Plan originally released on August 15, 2016.

The original plan identified 281 guidance projects as priorities, and the first quarter update includes an additional six guidance projects.  The additional projects include:

  • Guidance regarding the removal of the no-rule positions for certain legal issues concerning device and business purpose under section 355 (PUBLISHED 09/12/16 in IRB 2016-37 as REV. PROC. 2016-45 (RELEASED 08/26/16)).
  • Revenue procedure providing a self-certification procedure for waivers of the 60-day rollover requirement under §§402(c)(3) and 408(d)(3) (PUBLISHED 09/12/16 in IRB 2016-37 as REV. PROC. 2016-47 (RELEASED 08/24/16)).
  • Announcement on hardship distributions and loans from retirement plans as a result of Louisiana storms (PUBLISHED 09/12/16 in IRB 2016-37 as ANN. 2016-30 (RELEASED 08/30/16)).
  • Announcement concerning the tax treatment of payments made on behalf of or reimbursements received by residents affected by the Southern California Gas Company natural gas leak (PUBLISHED 08/01/16 in IRB 2016-31 as ANN. 2016-25 (RELEASED 07/19/16)).
  • Guidance for income and employment tax purposes on the treatment of cash payments made by employers under leave-based donation programs for the relief of victims of the Louisiana storms (PUBLISHED 10/03/16 in IRB 2016-40 as NOT. 2016-55 (RELEASED 09/16/16); and
  • Guidance under §909 related to foreign-initiated adjustments and the separation of foreign taxes and related income (PUBLISHED 10/03/16 in IRB 2016-40 as NOT. 2016-52 (RELEASED 09/15/16)).
Elizabeth EricksonElizabeth Erickson
  Elizabeth Erickson provides legal counsel on complex civil tax controversies, including tax litigation and transfer pricing matters. She has extensive experience in resolving domestic and international tax matters at all stages of dispute, including Internal Revenue Service examinations, administrative appeals, and litigation in the US Tax Court and district courts. She has advocated for clients before the Internal Revenue Service National Office, negotiated Advance Pricing Agreements with the Internal Revenue Service and other tax authorities, and resolved disputes through the Competent Authority process. Read Elizabeth Erickson's full bio.


K. Christy Vouri-MissoK. Christy Vouri-Misso
  K. Christy Vouri-Misso focuses her practice on all stages of complex federal tax controversies including Internal Revenue Service (IRS) examinations, administrative appeals, voluntary disclosures, and litigation. She has settled multiple tax disputes with IRS legal counsel avoiding costly litigation in court. Read K. Christy Vouri-Misso's full bio.

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