Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 6 – 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.
April 8, 2020: The IRS announced that four LB&I campaigns related to agricultural chemicals security credit, partial disposition election for buildings, restoration of sequestered alternative minimum tax credit carryforward and work opportunity tax credit have been retired. Even though these issues are no longer LB&I campaigns, such issues may still be identified and included in the scope of an LB&I examination.
April 8, 2020: The IRS released Revenue Procedure 2020-23, allowing for eligible partnerships to file amended partnership returns for taxable years beginning in 2018 and 2019 by using Form 1065, US Return of Partnership Income, checking the “Amended Return” box and issuing an amended Schedule K-1 to each of its partners.
April 9, 2020: The IRS issued Revenue Procedure 2020-24, which provides guidance regarding (i) an election under section 172(b)(3) to waive the carryback period for a net operating loss (NOL) arising in a taxable year beginning after December 31, 2017 and before January 1, 2020, (ii) excluding from the carryback period any taxable year in which the taxpayer has a section 965(a) inclusion, and (iii) for an NOL incurred in a taxable year that began before January 1, 2018 and ended after December 31, 2017, waiving or reducing the carryback period or revoking a prior election to waive the carryback period.
April 9, 2020: The IRS released Notice 2020-26, which provides for a six-month extension for the deadline for filing an application for a tentative carryback adjustment under section 6411 with respect to the carryback of an NOL that arose in any taxable year that began during calendar year 2018 and that ended on or before June 30, 2019.
April 10, 2020: The IRS issued Revenue Procedure 2020-22 to provide guidance regarding the election under section 163(j)(7)(B) to be an electing real property trade or business and the election under section 163(j)(7)(C) to be an electing farming business for purposes of the business interest expense deduction limitation under section 163(j).
April 10, 2020: The IRS and the Treasury Department launched a new web tool to allow people who do not normally file a tax return to register for Economic Impact Payments. The new web tool is intended to be simple and only take taxpayers a few minutes to register.
April 10, 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 Emily Mussio in our Chicago office for this week’s roundup.