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Weekly IRS Roundup August 9 – August 13, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 9, 2021 – August 13, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 10, 2021: The IRS issued Revenue Procedure 2021-33 and an accompanying news release, providing a safe harbor pursuant to which employers are permitted to exclude certain amounts from gross receipts for purposes of determining Employee Retention Credit eligibility.

August 10, 2021: The IRS issued Notice 2021-43 and an accompanying news release, providing relief for employers to claim the Work Opportunity Tax Credit under Section 51 of the Code with respect to employees who began work after December 31, 2020. This latest update is in response to the extension of the associated Empowerment Zone designations through December 31, 2025, and pursuant to the Taxpayer Certainty and Disaster Tax Relief Act of 2020.

August 10, 2021: The IRS issued a news release as part of a Security Summit series in partnership with state tax agencies and the tax industry, advising tax professionals to guard against pandemic-related phishing scams.

August 11, 2021: The IRS issued Revenue Procedure 2021-34, updating and modifying procedures for taxpayers to obtain automatic consent for certain income tax accounting method changes made to comply with Section 451 of the Code, as amended by the Tax Cuts and Jobs Act (TCJA).

August 11, 2021: The IRS issued Revenue Procedure 2021-35, modifying procedures for the safe harbor method of accounting for original issue discounts on a pool of credit card receivables in response to changes made to Section 451 by the TCJA.

August 13, 2021: The IRS issued Announcement 2021-13, announcing that the United States and United Kingdom have entered into an arrangement providing that references to the North American Free Trade Agreement (NAFTA) in the US-UK income tax treaty are to be interpreted as references to the United States-Mexico-Canada Agreement (USMCA) upon the USMCA’s entry into force.

August 13, 2021: The IRS issued Announcement 2021-14, announcing that the United States and United Kingdom have entered into an arrangement providing that, notwithstanding the United Kingdom’s withdrawal from the European Union, UK residents will continue to be treated as “equivalent beneficiaries” for purposes of applying the derivative benefits test to trusts under the Limitation on Benefits provision of the US-UK income tax treaty.

August 13, 2021: The IRS issued a news release announcing the disbursement of the August round of advance payments of the Child Tax Credit, consisting of approximately 36 million payments worth approximately $15 billion.

August 13, 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 [...]

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Weekly IRS Roundup July 13 – July 17, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 13, 2020 – July 17, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 14, 2020: The IRS issued a news release on a proposed redesigned partnership form for tax year 2021 (filing season 2022). The proposed form is designed to provide greater clarity for partners on how to compute their US income tax liability with respect to items of international tax relevance, including claiming deductions and credits. Comments are due by September 14, 2020.

July 16, 2020: The IRS issued a notice requesting comments concerning consent to extend the time to assess tax with respect to gain recognition agreements covered by section 367 of the Internal Revenue Code (Code). Form 8838 is used to extend the statute of limitations for US persons who transfer stock or securities to a foreign corporation. The form is filed when the transferor makes a gain recognition agreement. This agreement allows the transferor to defer the payment of tax on the transfer. The IRS uses Form 8838 so that it may assess tax against the transferor after the expiration of the original statute of limitations. Comments are due on or before September 14, 2020.

July 16, 2020: The IRS released various prescribed rates for federal income tax purposes for August 2020, including the applicable federal rates under section 1274(d); the adjusted applicable federal rates under section 1288(b); the adjusted federal long-term rate and the long-term tax-exempt rate under section 382(f); the appropriate percentages for determining the low-income housing credit under section 42(b)(1); and 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.

July 17, 2020: The IRS provided a notice of public hearing on proposed regulations clarifying that certain deductions allowed to an estate or non-grantor trust are not miscellaneous itemized deductions and thus are not affected by the suspension of the deductibility of miscellaneous itemized deductions for taxable years beginning after December 31, 2017, and before January 1, 2026. The proposed regulations also provide guidance on determining the character, amount and allocation of deductions in excess of gross income succeeded to by a beneficiary on the termination of an estate or non-grantor trust. The public hearing is being held on Wednesday, August 12, 2020, at 10:00 am. The IRS must receive speakers’ outlines of the topics to be discussed at the public hearing by Wednesday, July 29, 2020.

July 17, 2020: The IRS released a Competent Authority Arrangement between the authorities of Switzerland and the United States regarding the interpretation of the term “North American Free Trade Agreement” (NAFTA). NAFTA is being superseded by the US-Mexico-Canada Agreement [...]

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International News III 2017 | Brexit & the US Administration

McDermott Will & Emery recently published Issue 3, 2017 of International News, which covers a range of legal developments of interest to those operating internationally.

This issue focuses on the upcoming Brexit from the European Union and the changes in the US Administration; both subjects which have dominated headlines over the past year. This issue explores ways in which prepared investors and businesses can continue to function effectively during this period of uncertainty and change.

Read full issue.




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