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Weekly IRS Roundup June 1 – June 5, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. June 2, 2020: The IRS reminded taxpayers who live and work abroad that they have until July 15, 2020, to file their 2019 federal income tax return and pay any tax due. Typically, the deadline for such returns is June 15. June 3, 2020: The IRS issued Notice 2020-42 to provide temporary relief from the physical presence requirement in Treasury Regulations § 1.401(a)-21(d)(6) for participant elections required to be witnessed by a plan representative or a notary public, including a spousal consent required under IRC § 417. June 4, 2020: The IRS issued Notice 2020-39 and updated the Qualified Opportunity Zones frequently asked questions (FAQs). Notice 2020-39 answers questions regarding relief from certain...

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Weekly IRS Roundup May 25 – May 29, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 25 – May 29, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. May 26, 2020: The IRS and United States Department of the Treasury issued proposed regulations to provide guidance on federal income tax withholding on certain periodic retirement and annuity payments under IRC § 3405(a). May 26, 2020: The IRS and Treasury issued final regulations clarifying the reporting requirements under IRC § 6033, generally applicable to tax-exempt organizations. May 26, 2020: The IRS Practice Unit titled Taxation on the Disposition of USRPI by Foreign Persons was updated to clarify that publicly traded stock of a corporation continues to not be US real property interests (USRPI) if held by a 5% or less shareholder. The 5% threshold was increased to 10% only for real estate investment...

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Weekly IRS Roundup February 10 – 14, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020:  The IRS issued a revenue ruling providing guidance regarding how to determine the adjusted basis life of insurance contracts under IRC section 1011 and 1012 given the recent amendments to IRC section 1016(a), which the Tax Cuts and Jobs Act amended to provide that in determining the basis of a life insurance contract or an annuity contract, no adjustment is made for mortality, expense, or other reasonable charges incurred under the contract. The IRS updated Revenue Ruling 2009-13 and 2009-14 to reflect these changes. February 10, 2020:  The Joint Committee on Taxation released a report addressing domestic corporations’ federal tax receipts and tax liabilities. The report summarized the present law and accounting rules regarding corporate taxation, specifically addressing behavioral responses...

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Weekly IRS Roundup February 3 – 7, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 3 – 7, 2020. February 3, 2020:  The IRS and the Departments of Labor and Health and Human Services jointly announced frequently asked questions about the implementation of the Affordable Care Act. The agencies noted that they are tasked with developing standards for use by a group health plan and a health insurance issuer offering group or individual health insurance coverage in compiling a summary of benefits and coverage (SBC). The 2021 iterations of the SBC template, instructions, coverage example guide and narratives—all of which have been recently released—must be used beginning with the first day of the first open enrollment period for any plan year beginning on or after January 1, 2021. February 4, 2020:  The IRS issued an issue snapshot regarding self-dealing under IRC section 4941(d), focusing largely on the...

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Weekly IRS Roundup January 20 – 24, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 20 – 24, 2020. January 20, 2020: The IRS released new Instructions to IRS Form 1120-S, US Income Tax Return for an S Corporation. These changes conform to the new regulations, which changed the qualified business income deduction, addressed qualified opportunity fund investments, and removed the AMT refundable credit. In conjunction with these changes, the IRS also released updated Instructions to Form 1065, Partner’s Share of Income, Deductions, Credits, etc., so that it complied with the new rules regarding the qualified business income deduction. January 21, 2020: The IRS issued a notice updating both the corporate bond weighted average interest rates and the permissible range of interest rates used to calculate pension plan minimum funding for plan years beginning in January 2020. The IRS updated various projections,...

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Weekly IRS Roundup November 4 – 8, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International active compliance campaign on Section 965 transition tax as enacted under the 2017 TCJA. The IRS stated that the goal of the campaign is to promote compliance with Section 965. The treatment stream will include conducting examinations as well as providing technical assistance to teams on Section 965, with a focus on identifying and addressing taxpayer populations with potential material compliance risk. The IRS anticipates that returns selected as part of the Section 965 campaign will also be risked and, if appropriate, examined for other material issues, especially issues related to TCJA planning.  For our coverage of this campaign, see here. November 6, 2019: The IRS issued a Revenue Procedure and a News Release announcing the tax year 2020...

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IRS Issues Transition Tax Compliance Campaign

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of several dozen compliance campaigns that LB&I has announced since the initial 13 campaigns were identified in 2017, and is part of LB&I’s larger goals of improving return selection, identifying issues representing a risk of noncompliance and making the greatest use of limited resources. We have written at length regarding the IRS’s campaigns. Click here for prior coverage of the IRS’s campaigns. This announcement comes just over a month after the Treasury Inspector General for Tax Administration (TIGTA) issued a report questioning the effectiveness and efficiency of campaign issue selection. We wrote about the TIGTA report here. The IRS is presumably heeding TIGTA’s recommendation and is focused on Section 965 because of the...

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Tax Blog: New Questions and Answers for Section 965

The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or triggering events, and other matters related to S corporation shareholders making the section 965(i) election. Consistent with prior advice issued by the IRS (see coverage here and here), the Questions and Answers provide that the IRS cannot make a refund or apply as a credit any amount of an installment payment until the entire income tax liability is satisfied (i.e., any overpayments of an installment obligation will be used to satisfy future section 965 installment payments). The Questions and Answers also provides details on payment obligations with respect to successive installment payments under section 965(h). In particular, the IRS will “make every effort to issue an installment notice and payment voucher” for each successive...

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