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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.

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IRS Releases Several Transfer Pricing Directives

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division recently released several directives (LB&I Directives) geared toward transfer pricing. LB&I acknowledges that significant LB&I resources are devoted to transfer pricing issues, and such issues make up a substantial portion of the LB&I inventory. It appears that these directives are aimed at ensuring that LB&I resources are utilized in the most efficient and effective manner on transfer pricing issues. A link to each LB&I Directive and a short summary is provided below.

Interim Instructions on Issuance of Mandatory Transfer Pricing Information Document Request (IDR) in LB&I Examinations

This LB&I Directive advises LB&I examiners that it is no longer necessary to issue the mandatory transfer pricing information document request (IDR) to taxpayers that have filed Form 5471, Information Return of U.S. Person with Respect To Certain Foreign Corporations, or Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, or engaged in cross-border transactions. An update to Part 4.60.8 of the Internal Revenue Manual will be made in the future to further explain this change. (more…)

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