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Weekly IRS Roundup March 27 – April 2, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 29, 2022: The IRS issued a news release reminding taxpayers that the limitation on the educator expenses deduction of section 62(a)(2)(D) of the Code has risen from $250 to $300 for the 2022 taxable year.

March 29, 2022: The IRS issued a news release reminding taxpayers about, and providing information with respect to, filing extension options for individual income tax returns.

March 30, 2022: The IRS issued Revenue Procedure 2022-21, providing updates to the nationwide average purchase price for US residences and average purchase prices for different regional areas, for use in applying section 143 of the Code (relating to qualified mortgage bonds) and section 25 of the Code (relating to qualified mortgage credit certificates).

March 30, 2022: The IRS released Announcement 2022-07, providing the annual report on the Advance Pricing and Mutual Agreement Program and the advance pricing agreements (APAs) executed thereunder during calendar year 2021.

March 30, 2022: The IRS issued a news release providing various resources regarding claiming the 2021 Recovery Rebate Credit, as enacted by the American Rescue Plan Act of 2021 (ARPA).

March 31, 2022: The IRS issued a news release reminding taxpayers of the April 15, 2022 deadline for filing the Report of Foreign Banks and Financial Accounts (FBAR).

April 1, 2022: The IRS issued a news release announcing the appointment for 2022 of 25 new members to the Taxpayer Advocacy Panel, an advisory body that receives taxpayer feedback and makes suggestions for improving IRS customer service.

April 1, 2022: 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 August 30 – September 3, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 30, 2021 – September 3, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 30, 2021: With September being National Preparedness Month, the IRS reminded everyone to develop an emergency preparedness plan—especially with the height of hurricane season approaching and the ongoing wildfires. To prepare, taxpayers should secure and duplicate essential tax and financial documents.

August 31, 2021: The IRS postponed various tax filing and payment deadlines for victims of Hurricane Ida. Affected individuals and businesses will have until January 3, 2022, to file returns and pay any taxes that were originally due during this period. This means individuals who had a valid extension to file their 2020 return due to run out on October 15, 2021, will now have until January 3, 2022, to file. However, tax payments related to 2020 tax returns that were due on May 17, 2021, are not eligible for this relief. This extension also applies to quarterly estimated income tax payments due on September 15, 2021.

September 1, 2021: The IRS issued a practice unit on general principles for foreign tax credits, specifically addressing foreign tax credits as changed by the Tax Cuts and Jobs Act of 2017.

September 2, 2021: The IRS issued final regulations, modifying previous regulations relating to IRS administrative proceedings, to reflect limitations that are required by the enactment of the Taxpayer First Act of 2019. The regulations implement new rules regarding the persons who may be provided books, papers, records or other data obtained pursuant to Internal Revenue Code Section 7602 for the sole purpose of providing expert evaluation and assistance to the IRS. The regulations adopt further limitations on the type of non-governmental attorneys to whom any books, papers, records or other data may be provided. Under the final regulations, IRS contractors are prohibited from asking substantive questions of a summoned witness under oath or asking a summoned person’s representative to clarify an objection or assertion of privilege.

September 3, 2021: The IRS issued Revenue Procedure 2021-40, announcing that it will not issue private letter rulings or determination letters on whether certain transactions are considered an act of self-dealing under Internal Revenue Code Section 4941.

September 3, 2021: The IRS issued Notice 2021-52, providing travel per diem rates for 2021 – 2022.

September 3, 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 Emily Mussio in our Chicago office for this week’s roundup.




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 taxpayers.

May 20, 2020:  The IRS announced that Andy Keyso has been selected to serve as the Chief of the IRS Independent Office of Appeals, the IRS announced. For more information on Mr. Keyso and IRS Appeals, see our write-up here.

May 21, 2020:  The IRS announced that the 2020 IRS Nationwide Tax Forums will be held virtually in 2020 with a series of live-streamed webinars beginning this July. The 2020 Nationwide Tax Forums will begin on July 21 and continue through August 20.

May 22, 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 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 of rental services are performed per year; (3) taxpayer maintains contemporaneous records on hours of services performed, description of services, dates of services, and who performed such services; and (4) taxpayer attaches a statement with information such as a description of the properties, to a timely filed original return for each year in which the enterprise relies on the safe harbor. 

September 26, 2019: The Treasury and the IRS released proposed regulations that: (1) clarify the application of the employer shared responsibility provisions and certain nondiscrimination rules to reimbursement arrangements (HRAs) and other account-based group health plans integrated with individual health insurance coverage or Medicare (individual coverage HRAs); (2) provide certain safe harbors with respect to the application of those provisions to individual coverage HRAs; and (3) facilitate the adoption of individual coverage HRAs by employers by permitting taxpayers to rely on the proposed regulations. The proposed regulations would affect employers, employees and their family members, and plan sponsors.

September 27, 2019: The IRS released a Statistics of Income Bulletin focusing on individual income tax returns. The report contains data on sources of income, adjusted gross income, exemptions, deductions, taxable income, income tax, modified income tax, tax credits, self-employment tax, and tax payments. The report makes classifications by tax status, size of adjusted gross income, marital status, type of tax computation and age.

September 27, 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 Robbie Alipour in our Chicago office for this week’s roundup.




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 treatment of their payments.

November 20, 2018: The IRS in IRS Tax Reform Tax Tip 2018-179 advises that certain taxpayers may benefit from converting an S corporation into a C corporation due to the new, 21 percent tax rate.

November 23, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Alex Cheng-Yi Lee in our DC office for this week’s roundup.




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 Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Alex Cheng-Yi Lee in our DC office for this week’s roundup.




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 2018-31. This is a very important method change that affects many taxpayers who have to comply with ASC 606.

September 20, 2018: The IRS announced in Notice 2018-72 that it intends to amend the section 871(m) regulations to delay the effective date of certain provisions.

September 21, 2018: Treasury and the IRS published proposed regulations that would remove from the section 385 regulations minimum documentation requirements that must be satisfied for certain related-party debt to be respected as such for tax purposes. We previously commented on this here.

September 21, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Kevin Hall in our DC office for this week’s roundup.




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 certain non-corporate taxpayers during tax years beginning after December 31, 2018. The proposed regulations address which taxpayers are eligible for the deduction and provide guidance regarding the computation of the deduction.

August 8, 2018: The IRS released Notice 2018-64, which includes a proposed revenue procedure that would provide guidance regarding calculating W-2 wages for purposes of the section 199A deduction.

August 10, 2018: The IRS released their weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Kevin Hall in our DC office for this week’s roundup.




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 other changes and removing T.D. 9788.

June 19, 2018: The IRS released a Practice Unit on “Interest Capitalization for Self-Constructed Assets,” which identifies taxpayers subject to Code Section 263A(f) and covers the steps involved in determining how much interest must be capitalized to the basis of designated property.

June 20, 2018: IRS published Rev. Proc. 2018-35 modifying Rev. Proc. 2018-31, to not apply Section 263A to replanting costs for lost or damaged citrus plants pursuant to Code Section 263A(d)(2)(C).

June 21, 2018: The IRS published Notice 2018-48 listing the population census tracts designations by the Treasury for qualified opportunity zones relevant to new Code Section 1400Z-2.

June 22, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Christy Vouri-Misso and Greg Berson in our DC office for this week’s round-up.




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