Weekly IRS Roundup October 19 – October 23, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 19, 2020 – October 23, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 20, 2020: The IRS released Announcement 20-40 regarding the effective date of the termination of the shipping agreement between the United States and Hong Kong.

October 22, 2020: The IRS released Draft Instructions to Form 1065, which include revised instructions for partnerships required to report capital accounts to partners on Schedule K-1 (Form 1065).

October 23, 2020: The IRS released a statement notifying taxpayers that the IRS will resume issuing 500 series balance due notices.

October 23, 2020: The IRS released Internal Revenue Bulletin 2020-44, dated October 26, 2020, containing the following highlights: TD 9924 (Employment Tax) and TD 9910 (Income Tax).

October 23, 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.



Tax Court to Update Case Management System

The US Tax Court (Tax Court) recently announced upcoming changes to its case management system. DAWSON (Docket Access Within a Secure Online Network), named after former Tax Court Judge Howard A. Dawson, Jr., who passed away in 2016, is expected to be active by the end of 2020.

To facilitate the transition to DAWSON, the Tax Court’s current e-filing system will become inaccessible and all electronic files will become read-only beginning at 5:00 pm EST on November 20, 2020. Cases will remain electronically viewable, but no documents may be e-filed during this time. Importantly, no orders or opinions are anticipated to be issued during the transition.

Due to the lack of e-filing during the transition, Tax Court judges are trying to avoid setting deadlines that fall within this period. If a filing is required, it must be done the old-fashioned way on paper and by mail, with a proper certificate demonstrating service on the opposing party.

Notable improvements in DAWSON include:

  • Electronic filing of petitions and payment of filing fee
  • More user-friendly interface
  • Web-based, mobile-friendly and fully integrated system.

Practitioners should be on the lookout for an email from the Tax Court to set up their new account on DAWSON.

Practice Point: DAWSON will represent a significant upgrade for Tax Court practitioners. The addition of e-filing for petitions is particularly noteworthy as taxpayers and their representatives will not have to worry about potential problems and delays associated with physically mailing petitions to commence a case in Tax Court.



Weekly IRS Roundup October 12 – October 16, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 12, 2020 – October 16, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 13, 2020: The IRS published final regulations related to the absorption of consolidated net operating loss (CNOL) carryovers and carrybacks, as well as consolidated groups that include both life insurance companies and other companies.

October 14, 2020: The IRS released a draft of instructions for Form 5472 related to an information return of a 25% foreign-owned US corporation or a foreign corporation engaged in a US trade or business.

October 16, 2020: The IRS published Revenue Ruling 2020-22 updating the applicable federal rate (AFR) for November 2020.

October 16, 2020: The IRS published Notice 2020-47 updating the weighted average interest rate, the yield curve and segment rates used by certain benefit plans.

October 16, 2020: The IRS published Revenue Procedure 2020-46, which adds that a distribution to a state unclaimed property fund is a permissible reason to self-certify eligibility for a waiver to the 60-day rollover requirement for qualified plans and individual retirement arrangements.

October 16, 2020: The IRS published Revenue Procedure 2020-43 providing the maximum amount that may be made newly available for the plan year for an excepted benefit health reimbursement arrangement.

October 16, 2020: The IRS released Internal Revenue Bulletin 2020-43, dated October 19, 2020, containing the following highlights: Notice 2020-70 (Administrative) and TD 9920 (Employment Tax).

October 16, 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.



Weekly IRS Roundup October 5 – October 9, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 5, 2020 – October 9, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 7, 2020: The IRS published final regulations related to the withholding tax and information reporting requirements for the sale, exchange or redemption of a partnership interest held by a foreign person.

October 7, 2020: The IRS published a draft of Publication 509 with draft tax calendars for 2021.

October 9, 2020: The IRS published Revenue Ruling 2020-19 related to changes in basis of computing life insurance reserves.

October 9, 2020: The IRS published Revenue Procedure 2020-44 to facilitate a transition from interbank offered rates to alternate reference rates.

October 9, 2020: The IRS released Internal Revenue Bulletin 2020-42, dated October 13, 2020, containing the following highlights: REG-110059-20 (Income Tax); TD 9908 (Income Tax).

October 9, 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.



Weekly IRS Roundup September 28 – October 2, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 29, 2020: The IRS published final regulations related to the source of income for certain property sales and modifying rules for determining whether foreign source income is effectively connected with a US trade or business.

September 29, 2020: The IRS published final regulations related to a wide range of foreign tax credit topics. The regulations provide guidance on 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 take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments and the treatment of certain payments under the global intangible low-taxed income provisions.

October 1, 2020: The IRS published Notice 2020-70 generally removing Form 1040NR, US Nonresident Alien Income Tax Return, from the list of returns that are administratively exempt from the electronic filing requirement.

October 1, 2020: The IRS published final regulations related to savings programs for eligible individuals with a disability under section 529A.

October 1, 2020: The IRS released an Office of Chief Counsel Notice related to settlement options for syndicated conservation easement transactions.

October 2, 2020: The IRS published Notice 2020-76 providing for transition relief related to information reporting requirements related to the Affordable Care Act.

October 2, 2020: The IRS updated the instructions for Form 8858: Information Return of US Persons with Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs) to reflect changes due to the COVID-19 pandemic.

October 2, 2020: The IRS released Internal Revenue Bulletin 2020-41, dated October 5, 2020, containing the following highlights: Announcement 2020-12 (Administrative); Rev. Proc. 2020-42 (Administrative); Rev. Rul. 2020-20 (Income Tax); Rev. Rul. 2020-21 (Income Tax); TD 9915 (Income Tax); Notice 2020-73 (Income Tax); Notice 2020-74 (Income Tax).

September 25, 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.



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