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Weekly IRS Roundup June 14 – June 18, 2021

by McDermott Will & Emery | Jun 21, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 14, 2021 – June 18, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

June 14, 2021: The IRS issued a news release unveiling updates to its online Non-Filer Sign-Up Tool, expanding the scope of the tool to assist families who do not normally file tax returns to register for and receive monthly advance payments of the Child Tax Credit (as expanded by the American Rescue Plan of 2021).

June 15, 2021: The IRS issued Revenue Ruling 2021-12, providing various prescribed interest rates for federal income tax purposes for July 2021.

June 16, 2021: The IRS issued corrections to final regulations published on January 5, 2021, regarding simplified accounting rules for small businesses under sections 263A, 448, 460 and 471 of the Code.

June 16, 2021: The IRS issued Notice 2021-37, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

June 17, 2021: The IRS issued Revenue Procedure 2021-28, providing procedures for taxpayers to change to the alternative depreciation system of accounting under section 168(g) of the Code with respect to certain residential real property placed in service prior to 2018 as required by the Taxpayer Certainty and Disaster Tax Relief Act of 2020.

June 17, 2021: The IRS issued Revenue Procedure 2021-29, providing simplified procedures for certain partnerships to file amended partnership returns to comply with the procedures for tax accounting with respect to residential real property discussed in Revenue Procedure 2021-28.

June 18, 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 May 24 – May 28, 2021

by McDermott Will & Emery | Jun 1, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 24, 2021 – May 28, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 24, 2021: The IRS issued a news release, announcing that the 2021 IRS Nationwide Tax Forum—an annual series of continuing education seminars for tax professionals—will be held virtually from July 20, 2021, through August 19, 2021.

May 26, 2021: The IRS issued a news release, announcing the disbursement of more than 1.8 million Economic Impact Payments worth more than $3.5 billion, bringing the total amount of disbursements under the American Rescue Plan Act of 2021 to nearly 167 million payments worth approximately $391 billion.

May 27, 2021: The IRS issued Revenue Ruling 2021-10 and an accompanying news release, setting forth the overpayment and underpayment interest rates under section 6621 of the Code for Q3 of 2021.

May 28, 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 May 17 – May 21, 2021

by McDermott Will & Emery | May 24, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 17, 2021 – May 21, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 17, 2021: The IRS issued Revenue Ruling 2021-9, providing various prescribed interest rates for federal income tax purposes for June 2021.

May 17, 2021: The IRS issued Revenue Procedure 2021-24, providing procedures for individuals who are not required to file federal income tax returns to receive advance Child Tax Credit payments and third-round Economic Impact Payments under the American Rescue Plan Act of 2021 (ARPA), as well as 2020 recovery rebate credits under earlier coronavirus-related legislation.

May 17, 2021: The IRS issued a news release, reminding taxpayers that May 17 is the filing deadline for most individual income tax returns and summarizing various e-filing and extension options.

May 17, 2021: The IRS issued a news release, announcing that the first monthly payments under the Child Tax Credit, as expanded by ARPA, will be made to eligible families on July 15, 2021.

May 18, 2021: The IRS issued Notice 2021-31 and an accompanying news release, providing guidance on the temporary premium assistance for Consolidated Omnibus Budget Reconciliation Act (COBRA) health insurance benefits, and the associated COBRA premium assistance credit, enacted by ARPA.

May 19, 2021: The IRS issued Notice 2021-33, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

May 19, 2021: The IRS issued a news release, summarizing various tax benefits available to individuals experiencing homelessness, the rural poor and other underserved groups and urging employers and community groups to spread information about such benefits and assist such individuals in filing 2020 tax returns.

May 20, 2021: The IRS issued a news release, urging taxpayers who missed the recent May 17 tax-filing deadline to file their tax returns as soon as possible to obtain refunds or limit penalties and interest.

May 21, 2021: The IRS issued Notice 2021-32, providing the 2021 inflation adjustment factors and reference prices for the renewable electricity production credit, refined coal production credit and Indian coal production credit under section 45 of the Code.

May 21, 2021: The IRS issued an Action on Decision, announcing that it would not acquiesce to Machacek v. Comm’r, 906 F.3d 429 (6th Cir. 2018), which held that the economic benefits of a compensatory split-dollar life insurance arrangement may be treated as a distribution under section 301 of the Code.

May 21, 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 November 30 – December 4, 2020

by McDermott Will & Emery | Dec 8, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 30, 2020: After releasing a pre-publication draft in early October, the IRS published TD 9926 in the Federal Register, which provides final regulations regarding withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the United States under section 1446(f).

December 3, 2020: The IRS released Rev. Rul. 2020-28 related to the determination of the rate of interest under section 6621.

December 3, 2020: The IRS released Draft Instructions to Form 8992 related to the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).

December 4, 2020: The IRS issued REG-111950-20 regarding passive foreign investment companies (PFICs) and the treatment of qualified improvement property under the alternative depreciation system.

December 4, 2020: The IRS issued TD 9936 regarding PFICs.

December 4, 2020: The IRS issued the Fall 2020 Statistics of Income Bulletin providing data about tax and information returns. The Bulletin highlights high-income tax returns for Tax Year 2017 and partnership returns for Tax Year 2018.

December 4, 2020: The IRS issued a Statement warning that employers will experience delays in receiving payments associated with Form 7200 Advance Payment of Employer Credits.

December 4, 2020: The IRS released Internal Revenue Bulletin 2020-50, dated December 7, 2020, containing the following highlights: Notice 2020-83 (Employee Plans); TD 9923 (Exempt Organizations); Rev. Proc. 2020-51 (Income Tax); Rev. Rul. 2020-26 (Income Tax); Rev. Rul. 2020-27 (Income Tax).

December 4, 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 August 26 – 30, 2019

by McDermott Will & Emery | Sep 3, 2019 | IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019.

August 26, 2019: The IRS released a Treasury Decision in which it issued correcting amendments to TD 9866 (i.e., the global intangible low-taxed income (GILTI) and Foreign Tax Credit Regulations pertaining to IRC §951A). The correcting amendments to Treasury Regulations Section 1.951A-2 include in the second sentence of paragraph (c)(4)(iv)(A)(2)(i), removing the language “paragraph (c)(4)(ii)(A)” and adding “paragraph (c)(4)(iii)(A)” in its place, and in the third sentence, removing the language “paragraph (c)(4)(ii)(B)” and adding “paragraph (c)(4)(iii)(B)” in its place, among other changes.

August 27, 2019: The IRS released a revenue procedure in which it added Georgia to the list of countries for which the United States has an automatic exchange of deposit interest information as related to certain nonresident alien individuals. This revenue procedure supersedes Rev. Proc. 2018-36.

August 28, 2019: The IRS issued a news release and a revenue procedure in which it announced that interest rates will remain the same for the calendar quarter beginning October 1, 2019, as they were in the prior quarter. Specifically, those rates are 5% for overpayments (4% for corporations), 2.5% for the portion of a corporate overpayment exceeding $10,000, 5% for underpayments, 7% for large corporate underpayments and, for taxpayers other than corporations, the overpayment and underpayment rate is the federal short-term rate plus 3 percentage points.

August 29, 2019: The IRS released a revenue procedure in which it set forth 2018 annual percentages for Foreign Insurance Companies carrying on US business. Specifically, the domestic asset/liability percentage was set at 118.3% for foreign life insurance companies and 201.2% for foreign property and liability insurance companies. The revenue procedure also published domestic investment yields of 4.5% for foreign life insurance companies and 3.5% for foreign property and liability insurance companies. The IRS stated that a foreign insurance company must compute its estimated tax payments for its investment income for such taxable years by using the greater of its actual effectively connected net investment income or its minimum net investment income using these percentages, except that such company may continue to use the prior year’s percentages, as published in Revenue Procedure 2018-45, if the due date of an installment is less than 20 days after the current procedure is published in the Internal Revenue Bulletin.

August 30, 2019: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Alex Ruff in our Chicago office for this week’s roundup.

Weekly IRS Roundup February 25 – March 1, 2019

by McDermott Will & Emery | Mar 4, 2019 | IRS Guidance, Tax Reform, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019.

February 25, 2019: The IRS issued Revenue Ruling 2019-05, announcing the interest rates for underpayments and overpayments under section 6621 of the Code, applicable for the calendar quarter beginning April 1, 2019.

February 26, 2019: The IRS issued a news release as part of its new Tax Time Guide series, providing information and online resources to help taxpayers understand the changes made by the Tax Cuts and Jobs Act.

February 27, 2019: The IRS released final regulations amending the utility allowance regulations concerning the low-income housing credit under section 42 of the Code.

February 27, 2019: The IRS issued a news release reminding taxpayers who owe federal taxes about potential restrictions on their ability to obtain or renew passports.

February 27, 2019: The IRS scheduled a public hearing for March 14, 2019, on the proposed regulations implementing the Tax Cuts and Jobs Act as it relates to the foreign tax credit.

February 28, 2019: The IRS issued Notice 2019-17, providing relief from underpayment penalties to farmers and fishermen in certain circumstances.

February 28, 2019: The IRS issued a news release as part of its new Tax Time Guide series, providing information and online resources to taxpayers about how to check refund status or pay additional tax owed.

March 1, 2019: 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 DC office for this week’s roundup.

Weekly IRS Roundup December 3 – 7, 2018

by McDermott Will & Emery | Dec 10, 2018 | IRS Guidance, Tax Reform, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 3 – 7, 2018:

December 4, 2018: The IRS issued a news release granting taxpayers an extra day, until Thursday, December 6, 2018, to file any return or pay any tax originally due on Wednesday, December 5, 2018, in light of the Executive Order closing all federal agencies on December 5, 2018, as a mark of respect for President George H.W. Bush.

December 4, 2018: The IRS issued Notice 2018-95, providing transition relief from the “once-in-always-in” condition for excluding part-time employees under Treas. Reg. § 1.403(b)-5(b)(4)(iii)(B).

December 6, 2018: The IRS in Revenue Ruling 2018-32 released the interest rates for underpayments and overpayments applicable for the calendar quarter beginning January 1, 2019.

December 7, 2018: The IRS issued Notice 2018-97, providing initial guidance on the application of section 83(i) of the Code, enacted in the Tax Cuts and Jobs Act, which allows qualified employees of privately held corporations to defer paying income tax—for up to five years—on the value of qualified stock options and restricted stock units granted to them by their employers.

December 7, 2018: 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 DC office for this week’s roundup.