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Weekly IRS Roundup April 12 – April 16, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 12, 2021 – April 16, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 12, 2021: The IRS issued proposed regulations setting forth requirements that certain foreign taxpayers must meet in order to obtain the benefits of investing in a qualified opportunity fund (QOF) under section 1400Z-2 of the Code. The proposed regulations also expand the flexibility of a disaster-related working capital safe harbor in the existing QOF regulations.

April 13, 2021: The IRS issued Notice 2021-24, extending previously announced relief from penalties for failure to make timely deposits of employment taxes. The Notice extends relief to apply to deposits reduced in anticipation of certain employment tax credits with respect to qualified leave wages and Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage premiums during 2021.

April 13, 2021: The IRS issued Notice 2021-27, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

April 13, 2021: The IRS issued a news release urging low and moderate income taxpayers to use IRS Free File to prepare and electronically file their tax returns.

April 14, 2021: The IRS issued Notice 2021-28, inviting the public to submit recommendations for items to be included on the 2021-2022 Priority Guidance Plan.

April 14, 2021: The IRS issued a news release announcing a fifth round of Economic Impact Payments consisting of over two million payments totaling over $3.4 billion, bringing the total amount of disbursements under the American Rescue Plan of 2021 to approximately 159 million payments worth more than $376 billion.

April 15, 2021: The IRS issued Revenue Ruling 2021-08, providing various prescribed interest rates for federal income tax purposes for May 2021.

April 15, 2021: The IRS issued a news release emphasizing that individuals experiencing homelessness may still qualify for tax benefits such as Economic Impact Payments and urged community groups and employers to share information and help such individuals file tax returns so that they can obtain such benefits.

April 16, 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 Le Chen in our Washington, DC, office for this week’s roundup.

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Weekly IRS Roundup June 1 – June 5, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

June 2, 2020: The IRS reminded taxpayers who live and work abroad that they have until July 15, 2020, to file their 2019 federal income tax return and pay any tax due. Typically, the deadline for such returns is June 15.

June 3, 2020: The IRS issued Notice 2020-42 to provide temporary relief from the physical presence requirement in Treasury Regulations § 1.401(a)-21(d)(6) for participant elections required to be witnessed by a plan representative or a notary public, including a spousal consent required under IRC § 417.

June 4, 2020: The IRS issued Notice 2020-39 and updated the Qualified Opportunity Zones frequently asked questions (FAQs). Notice 2020-39 answers questions regarding relief from certain requirements under IRC § 1400Z-2, particularly providing that if a taxpayer’s 180th day to invest in a qualified opportunity zone would have fallen on or after April 1, 2020, and before December 31, 2020, the taxpayer now has until December 31, 2020, to invest that gain into a qualified opportunity fund (QOF). In addition, Notice 2020-39 provides that the period between April 1, 2020, and December 31, 2020, is suspended for purposes of the 30-month period during which property may be substantially improved.

June 4, 2020: The IRS announced that the Office of Chief Counsel will be expanding its Virtual Settlement Days program. Settlement Days events are organized in effort to resolve US Tax Court cases by providing taxpayers not represented by counsel the opportunity to receive free tax advice from certain pro bono groups such as the Low Income Taxpayer Clinics (LITCs) and American Bar Association (ABA).Through this program, taxpayers can also discuss their Tax Court cases and resolve related tax issues with members of the IRS Office of Chief Counsel, the Independent Office of Appeals and Collection.Due to COVID-19, Settlement Days events are now virtual and allow for taxpayers and volunteers to join from any location. 

June 5, 2020: The IRS issued Notice 2020-43 to seek public comment on a proposed requirement for partnerships to use only one of two alternative methods described in Notice 2020-43 to satisfy the Tax Capital Reporting Requirement with respect to partnership taxable years that end on or after December 31, 2020. The two methods that a partnership may use to report, for each partner, are either (i) the partner’s basis in its partnership interest, reduced by the partner’s allocable share of partnership liabilities, as determined under IRC § 752 (Modified Outside Basis Method); or (ii) the partner’s share of previously taxed capital, as calculated under a modified version of Treas. Reg. § 1.743-1(d) (Modified Previously Taxed Capital Method).

June 5, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, [...]

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Weekly IRS Roundup January 27 – 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 27 – 31, 2020.

January 27, 2020: The Joint Committee on Taxation released a report regarding an overview of selected provisions and options relating to funding and financing infrastructure investments. The report addresses the use of private activity bonds, new markets tax credits, and the opportunity zones incentive to fund infrastructure projects. The House Ways and Means Committee has scheduled a hearing entitled “Paving the Way for Funding and Financing Infrastructure Investments” on January 29, 2020.

January 29, 2020: The IRS issued a notice stating that the health coverage tax credit (HCTC) has been extended for all coverage months beginning in 2020. The IRS explained that eligible individuals can receive a tax credit to offset the cost of their monthly health insurance premiums so long as they have qualified health coverage. This notice supersedes the October 2019 letter from the IRS advising participants in the HCTC program to seek alternative insurance options due to the expiration of the HCTC law in December 2019.

January 30, 2020: The IRS issued final regulations that update the due dates and available extensions of time to file certain tax returns and information returns. The dates are updated to reflect the statutory requirements set by section 2006 of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 and section 201 of the Protecting Americans from Tax Hikes Act of 2015. The regulations also remove a provision for electing large partnerships that was obsoleted by section 1101(b)(1) of the Bipartisan Budget Act of 2015.

January 31, 2020: The IRS issued a news release announcing that nearly 80% of the taxpayers that received a settlement offer letter while under audit for their participation in abusive micro-captive insurance transactions have elected to accept the IRS’ settlement terms. The IRS also announced that it is establishing 12 new examination teams that are expected to open thousands of audits in the coming months. Abusive micro-captives have been a recurring feature on the IRS “Dirty Dozen” list of tax scams since 2014.

January 31, 2020: The IRS issued a revenue procedure detailing its revision of Form 1023, Application for Recognition of Exemption under Section 501(c)(3), announcing that the Form must be filed electronically beginning January 31, 2020, subject to a 90-day grace period during which the IRS will continue to receive paper forms. The IRS also revised the Instructions to Form 1023.

January 31, 2020: The IRS revised Form 8996, Qualified Opportunity Fund (QOF), to reflect final regulations on the subject. Form 8996 allows corporations and partnerships to certify that they are organized to invest in qualified opportunity zone (QOZ) property and to report that the QOF meets the 90% investment standard that section 1400Z-2 imposes. The IRS also revised the Instructions to Form 8966.

January 31, 2020: The IRS released its weekly list of written determinations (e.g., Private [...]

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