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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.




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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Weekly IRS Roundup October 15 – 19, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 15 – 19, 2018:

October 16, 2018: The IRS issued Rev. Proc. 2018-54, which sets forth procedural rules for certain taxpayers that hold investments in one or more segregated asset accounts to elect to treat certain mortgage-backed securities as having deemed issuers for purposes of the diversification requirements of Internal Revenue Code (Code) Section 817(h).

October 17, 2018: The IRS, in Qualified Intermediaries News, reminded entities seeking Qualified Intermediary, Withholding Partnership or Withholding Foreign Trust status with a withholding agreement effective in 2018 that the deadline for submitting the applications is November 16, 2018.

October 18, 2018: The IRS issued Notice 2018-81, which describes the manner in which taxpayers should notify the IRS of revocation of an election to aggregate or disaggregate certain church-related organizations from treatment as a single employer under Code Section 414(c)(2)(C) and (D).

October 18, 2018: The IRS issued Notice 2018-84, which clarifies the suspension of the personal exemption deduction in the newly-added section 151(d)(5) under certain rules in section 36B and section 6011.

October 19, 2018: The IRS issued proposed regulations for investment in opportunity zones, providing guidance on under new Code Section 1400Z-2 relating to gains that may be deferred as a result of a taxpayer’s investment in a qualified opportunity fund.

October 19, 2018: The IRS issued Rev. Rul. 2018-19, which provides guidance on the requirement of original use with respect to land purchased after 2017 in qualified opportunity zones.

October 19, 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.




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