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Weekly IRS Roundup August 23 – August 27, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 23, 2021 – August 27, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 23, 2021: The IRS announced that the application period for the 2022 Compliance Assurance Process (CAP) program will run September 1 to November 1, 2021. Acceptance notices will be delivered in February 2022. The CAP program employs real-time issue resolution between taxpayers and the IRS to improve federal tax compliance by resolving problems prior to the filing of a tax return. To be eligible, applicants must: (1) have assets worth $10 million or more; (2) be a US publicly traded corporation with a legal requirement to prepare and submit US Securities and Exchange Commission (SEC) Forms 10-K, 10-Q and 8-K and (3) not under investigation by—or in litigation with—any government agency that would limit the IRS’s access to current tax records. The IRS’s CAP webpage can be found here.

August 25, 2021: The IRS announced that interest rates for the calendar quarter starting October 1, 2021, will remain the same and will be issued in Rev. Rul. 2021-17, dated September 13, 2021.

August 27, 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 August 20 – 24, 2018

Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 20 – 24, 2018:

August 21, 2018: The IRS and Treasury released Notice 2018-67, which provides guidance regarding separately calculating the unrelated business taxable income (UBTI) of each trade or business conducted by a tax-exempt entity. Section 512(a)(6), enacted as part of tax reform, requires this separate calculation by tax-exempt organizations with more than one unrelated trade or business.

August 21, 2018: The IRS and Treasury released Notice 2018-68, which provides guidance regarding new section 162(m). Section 162(m), enacted as part of tax reform, limits the deduction for compensation paid by a publicly traded corporation to a covered employee. The notice provides guidance regarding the “grandfather” exception for certain compensation arrangements in effect on November 2, 2017. See our commentary for more information.

August 22, 2018: The IRS released Revenue Procedure 2018-44, which provides guidance regarding accounting method changing resulting from the revocation or termination of an entity’s S corporation status. Revenue Procedure 2018-44 adds such accounting method changes to the list of “automatic changes” listed in Revenue Procedure 2018-31.

August 22, 2018: The IRS published a draft Form 8992 for computing global low-taxed intangible income and a draft Form 8993 for computing foreign derived intangible income.

August 23, 2018: The IRS published proposed regulations providing guidance regarding the availability of a charitable deduction when the taxpayer also receives (or expects to receive) a state or local tax credit for the contribution.

August 24, 2018: The IRS made it clear that US citizens and residents that are contractors or employees of contractors supporting US Armed Forces are eligible for the section 911 foreign earned income exclusion.

August 24, 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.




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