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Weekly IRS Roundup January 18 – January 22, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

On January 20, President Biden’s chief of staff, Ronald Klain, issued a memorandum freezing the publication of rules in the Federal Register pending additional review by presidential designees or appointees. As a result, there may be delays in the official publication of pending IRS actions.

January 19, 2021: The IRS released Notice 21-08 providing a waiver of the addition to tax for underpayment of estimated income tax by individual taxpayers, where the underpayment is attributable to the amendment to section 461(l)(1)(B) contained in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

January 19, 2021: The IRS issued Rev. Rul. 21-04 updating the applicable federal rate and various other prescribed rates for February 2021.

January 19, 2021: The IRS issued Notice 21-09 updating weighted average interest rates, yield curves and segment rates.

January 19, 2021: The IRS released Notice 21-06 waiving the requirement to file information returns or furnish payee statements related to certain COVID-19 relief programs.

January 19, 2021: The IRS posted Notice 21-11 extending relief for employers to withhold and pay certain taxes because of the ongoing COVID-19 pandemic.

January 19, 2021: The IRS posted Notice 21-10 extending and providing additional relief for Qualified Opportunity Funds and their investors because of the ongoing COVID-19 pandemic

January 19, 2021: The IRS announced Notice 21-13 providing relief for partnerships from certain penalties related to the reporting of partners’ beginning capital account balances.

January 22, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

January 22, 2021: The IRS released Internal Revenue Bulletin 2021-4, dated January 25, 2021, containing the following highlights: Rev. Proc. 2021-8 (Exempt Organizations); TD 9937 (Employee Plans); Rev. Proc. 2021-10 (Income Tax); Rev. Rul. 2021-2 (Income Tax); Ann. 2021-1 (Tax Conventions).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.




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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