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Weekly IRS Roundup May 25 – May 29, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 25 – May 29, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 26, 2020: The IRS and United States Department of the Treasury issued proposed regulations to provide guidance on federal income tax withholding on certain periodic retirement and annuity payments under IRC § 3405(a).

May 26, 2020: The IRS and Treasury issued final regulations clarifying the reporting requirements under IRC § 6033, generally applicable to tax-exempt organizations.

May 26, 2020: The IRS Practice Unit titled Taxation on the Disposition of USRPI by Foreign Persons was updated to clarify that publicly traded stock of a corporation continues to not be US real property interests (USRPI) if held by a 5% or less shareholder. The 5% threshold was increased to 10% only for real estate investment trusts (REITs) under the Protecting Americans from Tax Hikes Act of 2015 (PATH Act).

May 27, 2020: The IRS and Treasury issued Notice 2020-41 to modify prior IRS notices addressing the beginning of construction requirement for both the production tax credit for renewable energy facilities under IRC § 45 and the investment tax credit for energy property under IRC § 48.

May 27, 2020: The IRS announced that some Economic Impact Payments (EIPs) will be sent to taxpayers in the form of a prepaid debit card that will arrive in a plain envelope from “Money Network Cardholder Services.”

May 28, 2020: The IRS announced that taxpayers will be able to file Form 1040-X, Amended US Individual Income Tax Return, electronically this summer. Previously, Form 1040-X was only accepted through the mail.

May 28, 2020: The IRS and Treasury issued proposed regulations regarding the credit for carbon oxide sequestration under IRC § 45Q.

May 29, 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 Emily Mussio in our Chicago office for this week’s roundup.




Weekly IRS Roundup March 9 – 13, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 9 – 13, 2020.

March 10, 2020: The IRS published a practice unit on how to compute the alternative minimum foreign tax credit. The public unit includes the framework for computing such alternative minimum foreign tax credit under IRC section 59.

March 10, 2020: The IRS released revised instructions for various information returns for 2020. The instructions were updated to reflect the PATH Act accelerating the due date for filing Form 1099 that included nonemployee compensation to January 31. Additionally, Form 1097-BTC, Form 1098-C, Form 1098-F, Form 1098-MA, Form 1098-Q, Form 1099-CAP, Form 1099-LS, Form 1099-LTC, Form 1099-OID, Form 1099-Q, Form 1099-SA, and Form 1099-SB and its instructions have been converted from annual updates to continuous use forms and instructions.

March 11, 2020: The Chief Counsel’s Office adopted 14-point Times New Roman as the standard font for all documents filed with the US Tax Court.

March 11, 2020: The US Tax Court cancelled sessions in a number of cities to contain the spread of Coronavirus. Some major cities cancelled sessions as far out as March 30, 2020. For more coverage, see here.

March 12, 2020: The IRS released clarifications to the 2019 Partner’s Instructions for Schedule K-1. The changes affect Code F IRC section 743(b) positive income adjustments, Code V IRC section 743(b) negative income adjustments, Code AA IRC section 704(c) information, and Code AH information.

March 12, 2020: The IRS released Notice 2020-16, which provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under IRC section 417(e)(3), and the 24-month average segment rates under IRC section 430(h)(2). The notice also provides guidance as to the interest rate on 30-year Treasury securities under IRC section 417(e)(3)(A)(ii)(II) for plan years beginning before 2008 and the 30-year Treasury weighted average rate under IRC section 431(c)(6)(E)(ii)(I).

March 13, 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 Emily Mussio in our Chicago office for this week’s roundup.




Weekly IRS Roundup June 3 – 7, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019.

June 4, 2019: The IRS issued a news release noting that it granted tax relief to victims of severe storms, tornadoes, straight-line winds and flooding in Oklahoma by postponing until September 16, 2019, various tax return filing and tax payment deadlines that occurred starting on May 7— including quarterly estimated tax payments due on June 17 and employment and excise tax returns due on July 31.

June 4, 2019: The IRS released issued a news release announcing that it will stop its tax transcript faxing service in June and will amend the Form 4506 series to end third-party mailing of tax returns and transcripts in July as part of its efforts to protect taxpayers from identity thieves.

June 5, 2019: The IRS released issued a news release announcing a decrease in interest rates for the third calendar quarter beginning July 1, 2019.

June 5, 2019: The IRS, in a memorandum dated May 21, 2019, indicated that it was withdrawing Directive LB&I 04-0018-004, Reasonably Anticipated Benefits in Cost Sharing Arrangements, which provided instructions for examiners on transfer pricing issue selection related to reasonably anticipated benefits in cost sharing agreements.

June 7, 2019: The IRS released final regulations for Section 337(d) effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and preventing abuse of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The final regulations impose corporate-level tax on certain transactions in which property of a C corporation becomes the property of a REIT.

June 7, 2019: The IRS released proposed regulations dealing with the section 897(l) exception from taxation on gain or loss of a qualified foreign pension fund attributable to specified interests in US real property. The proposed regulations also provide rules for how to certify that a qualified foreign pension fund is not subject to withholding on some dispositions of, and distributions for, US real property interests.

June 7, 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.




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