Private Letter Rulings
Subscribe to Private Letter Rulings's Posts

Weekly IRS Roundup May 18 – May 22, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 18 – May 22, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. May 18, 2020:  The U.S. Tax Court announced that comments to the proposed amendments to the Rules of its Practice and Procedure should be emailed to Stephanie A. Servoss, Clerk of the Court, at Rules@ustaxcourt.gov. The Tax Court has not received mail since March 19, 2020. May 18, 2020:  The IRS added approximately 3,500 phone operators to answer Economic Impact Payment (EIP) questions. May 19, 2020:  The Large Business & International (LB&I) released information regarding the Swiss Bank Program Campaign. The program allows Swiss financial institutions to provide information on the U.S. persons with beneficial ownership of foreign financial accounts. The campaign will address noncompliance of such...

Continue Reading

Weekly IRS Roundup September 23 – 27, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe harbor under which a rental real estate enterprise will be treated as a trade or business for purposes of section 199A and the regulations thereunder. The IRS explained that if the safe harbor requirements are met, the rental real estate enterprise will be treated as a single trade or business as defined in section 199A(d) for purposes of applying the regulations under section 199A. Each rental real estate enterprise will be treated as a single trade or business if the following requirements are satisfied during the taxable year with respect to the rental real estate enterprise: (1) separate books and records are maintained to reflect income and expenses for each enterprise; (2) for enterprises in existence less than four years, 250 or more hours...

Continue Reading

Weekly IRS Roundup November 19 – 23, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 19 – 23, 2018: November 19, 2018: The IRS in a news release reminds taxpayers that the non-recognition treatment for like-kind exchanges under Code Section 1031 is now limited to certain exchanges of real property. November 19, 2018: The IRS issued the final regulations under Code Section 267A on allocating costs to certain property produced or acquired for resale by a taxpayer. November 19, 2018: The IRS issued Revenue Procedure 2018-56, expanding the list of changes of methods of accounting for which the taxpayers may obtain automatic consent under the regulations of Code Section 267A. November 20, 2018: The IRS issued a notice to request comments on Form W-8CE, Notice of Expatriation and Waiver of Treaty Benefits, which the taxpayers use to notify expatriating payers of information necessary to determine the proper tax...

Continue Reading

Weekly IRS Roundup November 5 – 9, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 5 – 9, 2018: November 6, 2018: The IRS added in “Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns” information concerning the filing of transfer agreements under Internal Revenue Code (Code) Section 965(h)(3) and Section 965(i)(2)(c). For our prior coverage related to the election to pay the transition tax under Code Section 965, see here, here and here. November 7, 2018: The IRS in IRS Tax Tip 2018-173 reminds taxpayers of the blended tax rate as a result of tax reform and provides guidance on the computation of the blended rate. November 8, 2018: The IRS in a notice announced that the charter for the Internal Revenue Service Advisory Council has been renewed for two years beginning October 17, 2018. November 9, 2018: The IRS released its weekly list of written determinations (e.g., Private...

Continue Reading

Weekly IRS Roundup September 17 – 21, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 17 – 21, 2018: September 17, 2018: The Treasury Inspector General for Tax Administration (TIGTA) released a report reviewing whether the IRS complied with legal and internal guidelines governing the seizure of property for unpaid taxes. September 17, 2018: TIGTA released a second report compiling statistical information reported by the IRS in order to provide information about how the IRS uses its compliance resources and the resulting tax collections. September 18, 2018: The IRS published Revenue Ruling 2018-17, which provides the applicable federal interest rate for October 2018 and other interest rates. September 19, 2018: The IRS published Revenue Procedure 2018-49, which allows taxpayers that early adopted a method of revenue recognition to change such method to one described in Section 16.11 of Revenue Procedure...

Continue Reading

Weekly IRS Roundup August 6 – 10, 2018

Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 6 – 10, 2018: August 6, 2018: The IRS and Treasury issued final regulations, which provide guidance regarding the new partnership audit rules. The regulations describe the procedure for designating a partnership representative and the partnership representative’s authority. They also address the time, form and manner of an election to apply the new audit regime to prior partnership tax years. August 6, 2018: The IRS published Revenue Procedure 2018-40, which describes procedures for small businesses to obtain automatic consent for changing an accounting method to a new method established under the TCJA (P.L. 115-97). August 7, 2018: The IRS published an updated subject matter directory, available here. August 8, 2018: The IRS published proposed regulations under new section 199A, which provides a 20 percent deduction for qualifying income earned by...

Continue Reading

Weekly IRS Roundup: June 18 – 22

Presented below is our weekly roundup for June 18-22, 2018 on significant IRS guidance and relevant tax matters. June 18, 2018: The IRS issued Internal Revenue Bulletin No. 2018-25 including: Rev. Rul. 2018-17 (withholding and reporting payments from IRAs to state unclaimed property funds under Internal Revenue Code (Code) Section 3405); and REG-102951-16 (proposing amendments to rules for determining whether information returns must be filed electronically). June 18, 2018: In IR-2018-139 the IRS stated that people with disabilities can now put more money into their tax-favored ABLE accounts and may, for the first time, qualify for the Saver’s Credit for low- and moderate-income workers. June 19, 2018: The IRS published Rev. Rul. 2018-19 listing the applicable federal interest rates for July 2018. June 19, 2018: The IRS proposed regulation REG-131186-17 to reinstate T.D. 9787, including allocations of excess nonrecourse liabilities of a partnership among...

Continue Reading

Yeehaw! McDermott’s Tax Weekly Round Up

Here’s what happened in the world of IRS guidance for the week June 11 - 15, 2018. June 11, 2018: The IRS issued Notice 2018-55 describing potential proposed regulations that would offer relief to some private colleges and universities by providing a stepped-up basis rule that could reduce the amount of gain subject to a new 1.4 percent excise tax on their endowments. June 12, 2018: The IRS issued proposed regulations, under Code section 148 applicable to tax-exempt and other tax-advantaged bonds, aimed to restrict arbitrage investments and providing an exception to the definition of investment-type property for capital projects that further the public purpose for which the bonds were issued. June 12, 2018: Pursuant to its continuing effort to reduce paperwork, the IRS requested comments on a number of published guidance, including: Rev. Proc. 2003-33 (extension of time to file a section 338 election to treat stock purchases as asset acquisitions); TD 8379...

Continue Reading

STAY CONNECTED

TOPICS

ARCHIVES