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Weekly IRS Roundup January 11 – January 15, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 11, 2021 – January 15, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. January 11, 2021: The IRS released TD 9948 containing final regulations relating to the excise taxes imposed on certain amounts paid for transportation of persons and property by air. January 11, 2021: The IRS released TD 9938 setting forth final regulations related to the excise tax on remuneration in excess of $1 million and any excess parachute payment paid by certain tax-exempt organizations to covered employees. January 12, 2021: The IRS released TD 9946 containing final regulations related to the deduction and reporting of certain fines, penalties and other amounts. January 13, 2021: The IRS released TD 9949 providing final regulations concerning the application of the employer shared...

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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...

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Let’s All Stop and Reflect for a Moment

In a recent article for the American Bar Association's ABA Tax Times, McDermott partner Andrew R. Roberson reflected on 2020 and the importance of giving back. “From COVID-19 to the Black Lives Matter movement; from home office and Zoom to remote learning for students; and so on—these events have impacted us all, both on professional and personal levels.” Access the article.

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Weekly IRS Roundup November 23 – November 27, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. November 23, 2020: The IRS released TD 9935, providing final regulations implementing statutory changes to the treatment of like-kind exchanges. November 23, 2020: The IRS issued a News Release announcing a research partnership to improve IRS procurement operations. November 24, 2020: The IRS released Notice 2020-84 announcing the adjusted applicable dollar amount for calculating the fee imposed by sections 4375 and 4376 for certain health plans. November 25, 2020: The IRS updated FAQs providing guidance on What Is an Eligible Employer for COVID-19-related tax credit purposes and How to Claim the Credits. November 27, 2020: The IRS released Internal Revenue Bulletin 2020-49, dated November 30,...

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Weekly IRS Roundup November 16 – November 20, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 16, 2020 – November 20, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. November 16, 2020: The IRS released Notice 2020-82 related to the due date for certain contributions to defined benefit plans. November 16, 2020: The IRS released Revenue Ruling 2020-26 updating the applicable federal rate and various other prescribed rates for December 2020. November 16, 2020: The IRS released Notice 2020-81 updating weighted average interest rates, yield curves, and segment rates. November 18, 2020: The IRS released Revenue Ruling 2020-27 related to deductions for expenses paid with Paycheck Protection Program (PPP) loans. November 18, 2020: The IRS released Revenue Procedure 2020-51 providing a safe harbor for deductions for expenses paid with PPP loans when loan...

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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...

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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...

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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,...

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Weekly IRS Roundup August 24 – August 28, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 24 2020: The IRS published a memorandum concerning guidance to the field on the criteria that should be applied in considering if a request for designation for litigation should be made to the Office of Chief Counsel. The memorandum also provides interim guidance on the requirements of Section 1001 of the Taxpayer First Act (TFA) with respect to the limitation on designation of cases as not eligible for referral to the IRS Independent Office of Appeals. August 25, 2020: The IRS published a Summer 2020 Statistics of Income Bulletin. The Summer 2020 Bulletin focuses individual income tax shares, 2017; foreign recipients of US income, calendar year 2017; effects of post-filing adjustments on...

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Weekly IRS Roundup August 3, 2020 – August 7, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 3, 2020 – August 7, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 3, 2020: The IRS published a news release announcing that James Lee will become the new chief of IRS Criminal Investigation on October 1, 2020.   August 4, 2020: The IRS published a notice and request for comments concerning Form 3800 (General Business Credit), which is the form taxpayers file to claim any of the general business credits. Comments are due on or before October 5, 2020. August 4, 2020: The IRS published corrections to final regulations under Treasury Decision 9896 that were published in the Federal Register on Wednesday, April 8, 2020. The final regulations provide guidance regarding hybrid dividends and certain amounts paid or accrued pursuant to hybrid arrangements, which...

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