CARES Act
Subscribe to CARES Act's Posts

Weekly IRS Roundup March 29 – April 2, 2021

Presented below is our summary of significant Internal Revenue Serve (IRS) guidance and relevant tax matters for the week of March 29, 2021 – April 2, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 29, 2021: The IRS issued Notice 2021-21 and an accompanying news release, extending certain individual income tax deadlines to May 17, 2021, including the deadline for making contributions to individual retirement accounts (IRAs) and health savings accounts (HSAs) and the deadline for claiming refunds.

March 30, 2021: The IRS issued corrections to final regulations published on January 15, 2021, regarding credits for carbon capture equipment under section 45Q of the Code.

March 30, 2021: The IRS released Announcement 2021-6, providing a report on advance pricing agreements for calendar year 2020 under the Advance Pricing and Mutual Agreement Program.

March 30, 2021: The IRS issued a news release warning students and staff of educational institutions of an IRS-impersonation phishing scam.

March 30, 2021: The IRS issued a news release announcing that it anticipates Economic Impact Payments will begin to be issued to Social Security recipients and other individuals who do not normally file tax returns starting the weekend of April 3.

March 30, 2021: The IRS issued a news release providing answers to frequently asked questions regarding the reporting of pandemic-related emergency financial aid grants by students and higher education institutions.

March 31, 2021: The IRS issued a news release announcing that it will take steps to provide automatic refunds to taxpayers who filed tax returns reporting unemployment compensation prior to changes made by the American Rescue Plan Act of 2021 (ARPA).

April 1, 2021: The IRS issued a news release announcing a third round of Economic Impact Payments consisting of four million payments totaling over $10 billion, bringing the total amount of disbursements under ARPA to more than 130 million payments worth approximately $335 billion.

April 2, 2021: The IRS issued Notice 2021-23 and an accompanying news release, providing guidance on the changes made by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 on the employee retention credit under the Coronavirus Aid, Relief and Economic Security (CARES) Act.

April 2, 2021: The IRS issued a news release soliciting civic-minded volunteers to serve on the Taxpayer Advocacy Panel, a federal advisory committee for identifying taxpayer concerns and making recommendations for improving IRS service and customer satisfaction.

April 2, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

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




Weekly IRS Roundup March 22 – March 26, 2021

Presented below is our summary of significant Internal Revenue Serve (IRS) guidance and relevant tax matters for the week of March 22, 2021 ­­– March 26, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 22, 2021: The IRS issued Notice 2021-22, providing guidance on various interest rates relevant to employee benefit plans.

March 22, 2021: The IRS issued a news release announcing that the next batch of Economic Impact Payments under the American Rescue Plan Act of 2021 (ARPA) would be issued to taxpayers this week.

March 24, 2021: The IRS issued a news release confirming, as previously announced, the disbursement of approximately 37 million Economic Impact Payments, bringing the total amount of disbursements under ARPA to approximately 127 million payments worth approximately $325 billion.

March 25, 2021: The IRS released Revenue Procedure 2021-19, providing guidance on median gross income figures, used by certain issuers of mortgage bonds and mortgage credit certificates.

March 25, 2021: The IRS issued a news release summarizing the proceedings from “The Challenge,” a meeting (held virtually this year) of the Joint Chiefs of Global Tax Enforcement (J5) regarding international coordination on tax crimes.

March 25, 2021: The IRS issued a news release noting the one-year anniversary of the Coronavirus Aid, Relief and Economic Security (CARES) Act and pledging the Criminal Investigation Division’s continued commitment to investigating COVID-19 fraud.

March 26, 2021: The IRS released Revenue Procedure 2021-17, providing guidance on average residence purchase prices, used by certain issuers of mortgage bonds and mortgage credit certificates.

March 26, 2021: The IRS released Revenue Procedure 2021-18, providing state and local governments in which an empowerment zone is located with an automatic procedure for extending the empowerment zone designation under section 1391(a).

March 26, 2021: The IRS issued Announcement 2021-5, announcing that the United States and Japan have entered into an arrangement regarding the implementation of the arbitration process provided for in the 2003 US-Japan tax treaty.

March 26, 2021: The IRS issued Announcement 2021-7, notifying taxpayers that amounts paid for personal protective equipment for the primary purpose of preventing the spread of COVID-19 are treated as deductible medical expenses under section 213.

March 26, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

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




Weekly IRS Roundup March 1 – March 5, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 1, 2021 – March 5, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 1, 2021: The IRS issued Notice 21-20 providing guidance regarding the employee retention credit provided under section 2301 of the Coronavirus Aid, Relief, and Economic Security Act. Specifically, Notice 21-20 addresses the employee retention credit as it applies to qualified wages paid after March 12, 2020, and before January 1, 2021.

March 2, 2021: The IRS issued Revenue Ruling 21-6, which provides certain applicable interest rates for the overpayments and underpayments of taxes. Specifically, Revenue Ruling 21-6 provides the daily compound interest for annual rates of 0.5% and the annual interest rates to be compounded daily pursuant to section 6622 that apply for prior periods.

March 2, 2021: The IRS issued Notice 21-15 providing guidance regarding the application of section 214 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020, which provides temporary special rules for health flexible spending arrangements and dependent care assistance programs under section 125 of the Internal Revenue Code.

March 4, 2021: The IRS released Internal Revenue Bulletin 2021-10, dated March 8, 2021, containing the following highlights: Notice 2021-16 (Employee Plans); Notice 2021-15 (Income Tax); and Rev. Rul. 2021-5 (Income Tax).

March 5, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Samuel DiPietro in our Chicago office for this week’s roundup.




Weekly IRS Roundup January 18 – January 22, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

On January 20, President Biden’s chief of staff, Ronald Klain, issued a memorandum freezing the publication of rules in the Federal Register pending additional review by presidential designees or appointees. As a result, there may be delays in the official publication of pending IRS actions.

January 19, 2021: The IRS released Notice 21-08 providing a waiver of the addition to tax for underpayment of estimated income tax by individual taxpayers, where the underpayment is attributable to the amendment to section 461(l)(1)(B) contained in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

January 19, 2021: The IRS issued Rev. Rul. 21-04 updating the applicable federal rate and various other prescribed rates for February 2021.

January 19, 2021: The IRS issued Notice 21-09 updating weighted average interest rates, yield curves and segment rates.

January 19, 2021: The IRS released Notice 21-06 waiving the requirement to file information returns or furnish payee statements related to certain COVID-19 relief programs.

January 19, 2021: The IRS posted Notice 21-11 extending relief for employers to withhold and pay certain taxes because of the ongoing COVID-19 pandemic.

January 19, 2021: The IRS posted Notice 21-10 extending and providing additional relief for Qualified Opportunity Funds and their investors because of the ongoing COVID-19 pandemic

January 19, 2021: The IRS announced Notice 21-13 providing relief for partnerships from certain penalties related to the reporting of partners’ beginning capital account balances.

January 22, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 22, 2021: The IRS released Internal Revenue Bulletin 2021-4, dated January 25, 2021, containing the following highlights: Rev. Proc. 2021-8 (Exempt Organizations); TD 9937 (Employee Plans); Rev. Proc. 2021-10 (Income Tax); Rev. Rul. 2021-2 (Income Tax); Ann. 2021-1 (Tax Conventions).

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




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 [...]

Continue Reading




Weekly IRS Roundup September 21 – September 25, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 21, 2020: The IRS released Announcement 2020-12 to detail information reporting requirements for taxpayers seeking forgiveness of Paycheck Protection Program loans under the Coronavirus Aid, Relief and Economic Security (CARES) Act.

September 21, 2020: The IRS published final regulations related to bonus depreciation. The rules provide additional guidance to final regulations issued in 2019.

September 21, 2020: The IRS published final regulations providing guidance for certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a trade or business within the United States.

September 21, 2020: The IRS published final regulations clarifying that certain deductions allowed to an estate or non-grantor trust are not miscellaneous non-itemized deductions.

September 22, 2020: The IRS issued proposed regulations to modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under section 367(a) and narrow the scope of foreign corporations that are treated as controlled foreign corporations for purposes of the look-through rule under section 954(c)(6).

September 22, 2020: The IRS published final regulations related to the downward attribution for ownership determination of controlled foreign corporations (CFCs) following changes in the Tax Cuts and Jobs Act.

September 24, 2020: The IRS announced that it will provide tax relief for victims of Hurricane Sally by extending the deadline for filing and payment deadlines that would have been due October 15, 2020, until January 15, 2021.

September 25, 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.

September 25, 2020: The IRS released Internal Revenue Bulletin 2020-40, dated September 28, 2020, containing the following highlights: Notice 2020-66 (Administrative); Announcement 2020-17 (Employee Plans Administrative); Notice 2020-72 (Employee Plans); Notice 2020-59 (Income Tax); Notice 2020-71 (Income Tax); REG-107911-18 (Income Tax); Rev. Proc. 2020-41 (Income Tax); Rev. Rul. 2020-19 (Income Tax); TD 9905 (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.




Weekly IRS Roundup September 14 – September 18, 2020

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

September 14, 2020: The IRS published final regulations providing guidance on the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the Tax Cuts and Jobs Act (TCJA) and the Coronavirus Aid, Relief and Economic Security Act (CARES Act). The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation and how the limitation applies in consolidated group, partnership, international and other contexts. The final regulations vary slightly from the document released on IRS.gov on July 28, 2020.

September 14, 2020: The IRS published a criminal tax bulletin concerning recent case law involving the Criminal Tax Division.

September 15, 2020: The IRS published Rev. Rul. 2020-20 that provides various prescribed rates for federal income tax purposes for October 2020, including: (1) the applicable federal rates (AFR) under section 1274(d); (2) the adjusted applicable federal rates (adjusted AFR) under section 1288(b); (3) the adjusted federal long-term rate and the long-term tax-exempt rate under section 382(f); (4) the appropriate percentages for determining the low-income housing credit under Section 42(b)(1); and (5) the federal rate for determining the present value of an annuity, an interest for life or for a term of years or a remainder or a reversionary interest under section 7520.

September 15, 2020: The IRS published a practice unit covering Last In-First Out (LIFO) inventories under various LIFO methods.

September 15, 2020: The IRS released for future publication in the Federal Register final regulations concerning the definition of an eligible terminated S corporation and rules relating to distributions of money by such a corporation after the post-termination transition period. The regulation package also amends current regulations to extend the treatment of distributions of money during the post-termination transition period to all shareholders of the corporation and clarifies the allocation of current earnings and profits to distributions of money and other property. The final regulations affect C corporations that were formerly S corporations and the shareholders of such corporations.

September 16, 2020: The IRS published a memorandum providing flexibility for taxpayers who are temporarily unable to meet the payment terms on accepted offers due to the economic impact of COVID-19. The procedures will expire December 31, 2020, unless extended.

September 17, 2020: The IRS published a practice unit providing an overview of the Overall Foreign Loss (OFL), Separate Limitation Loss (SLL) and Overall Domestic Loss (ODL) rules, as well as related examples.

September 17, 2020: The IRS
Continue Reading




Weekly IRS Roundup August 31 – September 4, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 1, 2020: The IRS released for publication in the federal register final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties.

September 1, 2020: The IRS announced the launch of the Bipartisan Budget Act (BBA) Centralized Partnership Audit Regime webpage. The Centralized Partnership Audit Regime replaces the Tax Equity and Fiscal Responsibility Act (TEFRA) and the electing large partnership rules. The centralized partnership audit regime, or BBA, is generally effective for tax years beginning January 2018. Under the BBA, the IRS generally assesses and collects any understatement of tax (called an imputed underpayment) at the partnership level.

September 1, 2020: The IRS published a memorandum providing guidance on the Bipartisan Budget Act of 2015 (BBA) until Internal Revenue Manual (IRM) 8.19 is revised. The guidance covers: (1) Appeals TEFRA Team (ATT) and Technical Guidance (TG) referrals; (2) Tax Court rules on BBA partnership proceedings; (3) Tax Computation Specialist (TCS) assistance; (4) Tried Cases and Counsel Settlements; (5) Tax Court Decision Appealed and Final Decision from Appeal; and (6) Department of Justice (DOJ) cases.

September 1, 2020: The IRS announced its intention to issue regulations addressing the application of sections 951 and 951A of the Internal Revenue Code (Code) to certain S corporations (as defined in section 1361(a)(1)) with accumulated earnings and profits, as described in section 316(a)(1) (AE&P). The notice also announces that the US Department of the Treasury and the IRS intend to issue regulations addressing the treatment of qualified improvement property (QIP) under the alternative depreciation system (ADS) of section 168(g) for purposes of calculating qualified business asset investment (QBAI) for purposes of the foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) provisions. Comments should be submitted by November 2, 2020.

September 1, 2020: The IRS requested comments on Revenue Procedure 2015-40 (that provides guidance for taxpayers who believe that the actions of the United States, a treaty country or both result or will result in taxation that is contrary to the provisions of an applicable tax treaty) to submit the requested information in order to receive assistance from the IRS official acting as the US competent authority. Comments are due on or before November 2, 2020.

September 3, 2020: The IRS released the fourth quarter update to the 2019–2020 Priority Guidance Plan. The fourth quarter update to the 2019-2020 plan reflects 53 additional projects which have been published [...]

Continue Reading




Weekly IRS Roundup July 27 – July 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 27, 2020 – July 31, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 28, 2020: The IRS issued final regulations providing guidance about the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the Tax Cuts and Jobs Act and the Coronavirus Aid, Relief and Economic Security Act (CARES Act). The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation and how the limitation applies in consolidated group, partnership, international and other contexts.

July 28, 2020: The IRS published a notice of proposed rulemaking concerning rules that provide additional guidance on various business interest expense deduction limitation issues not addressed in the final regulations, including more complex issues related to the amendments made by the CARES Act.

July 28, 2020: The IRS added frequently asked questions regarding the aggregation rules under section 448(c)(2) that apply to the section 163(j) small business exemption.

July 29, 2020: The IRS posted a practice unit on issues concerning the receipt of dividends or interest from a related controlled foreign corporation.

July 29, 2020: The IRS posted a practice unit on accuracy-related penalties under section 6662.

July 29, 2020: The IRS published a notice of proposed rulemaking concerning regulations to implement legislative changes to sections 263A, 448, 460 and 471 that simplify the application of those tax accounting provisions for certain businesses having average annual gross receipts that do not exceed $25 million, adjusted for inflation. The notice also contains proposed regulations regarding certain special accounting rules for long-term contracts under section 460 to implement legislative changes applicable to corporate taxpayers. The proposed regulations generally affect taxpayers with average annual gross receipts of not more than $25 million (adjusted for inflation). The IRS also requested comments regarding the application of section 460 (or other special methods of accounting) to a contract with income that is accounted for in part under section 460 (or other special method) and in part under section 451. Comments must be received by September 14, 2020.

July 31, 2020: The IRS published a notice of proposed rulemaking concerning proposed regulations that provide guidance under section 1061. Section 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains. The regulations also amend existing regulations on holding periods to clarify the holding period of a partner’s interest in a partnership that includes in whole or in part an applicable partnership interest and/or a profits interest. The regulations affect taxpayers who directly or indirectly [...]

Continue Reading




Weekly IRS Roundup July 20 – July 24, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 20, 2020 – July 24, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 20, 2020: The IRS published a news release on after-tax-day tips for taxpayers who missed the July 15, 2020, tax deadline and did not request an extension. The tips include advice on obtaining a refund and on reducing penalties and interest.

July 20, 2020: The IRS released public comments on the 2020-21 Priority Guidance Plan in response to Notice 2020-47, which invited the public to submit recommendations for items to be included on the 2020-2021 Priority Guidance Plan. The US Department of the Treasury and the IRS use the Priority Guidance Plan each year to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.

July 21, 2020: The IRS announced the creation of the new Enterprise Digitalization and Case Management office, which will spearhead IRS efforts to empower taxpayers and IRS employees to rapidly resolve issues in a simplified digital environment. The office’s efforts will support overall IRS modernization and implementation of long-term changes stemming from the Taxpayer First Act. The new stand-alone office will focus on enhancing the taxpayer experience by improving business processes and modernizing systems.

July 22, 2020: The IRS published a notice to solicit comments on Form 3800 (General Business Credit). Section 38 permits taxpayers to reduce their income tax liability by the amount of their general business credit, which is an aggregation of various credits. Form 3800 is used to figure the correct credit. Comments are due on or before September 21, 2020.

July 23, 2020: The IRS published a notice requesting comments on TD 8435 that provides final income, estate and gift, and employment tax regulations relating to elections made under the Technical and Miscellaneous Revenue Act of 1988. This regulation enables taxpayers to take advantage of various benefits provided by the Internal Revenue Code (Code). Comments are due on or before September 21, 2020.

July 23, 2020: The IRS published final regulations under the global intangible low-taxed income (GILTI) and subpart F income provisions of the Code regarding income subject to a high rate of foreign tax. The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their GILTI computation on an elective basis. The final regulations are effective on September 21, 2020.

July 23, 2020: The IRS also published proposed regulations that generally conform the rules implementing the subpart F high-tax exception to the rules implementing the GILTI high-tax exclusion set forth in the final regulations, and provided for a single election under section 954(b)(4) for purposes [...]

Continue Reading




STAY CONNECTED

TOPICS

ARCHIVES