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Weekly IRS Roundup September 3 – 7, 2018

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 3 – 7, 2018:

September 4, 2018: The IRS reminded taxpayers that they have until September 28, 2018, to apply for the Offshore Voluntary Disclosure Program.

September 5, 2018: In response to taxpayer inquiries, the IRS clarified that taxpayers generally can deduct business-related payments to charities or governmental entities even if they also receive a state or local tax credit.

September 6, 2018: The IRS released a Practice Unit on “Determining an Individual’s Residency for Treaty Purposes.”

September 6, 2018: The IRS published Revenue Procedure 2018-47, which provides guidance to regulated investment companies regarding the application of the section 4982 excise tax to amounts included in income under the new Internal Revenue Code (Code) Section 965 transition tax.

September 7, 2018: The IRS published Revenue Ruling 2018-25, establishing the interest rates applicable to over- and under-payments of tax.

September 7, 2018: The IRS released PMTA 2018-016, concluding that it can use it math error authority, not only on intake and before refunds have been issued, but also anytime within the three-year statute of limitations period under Code Section 6501(a).

September 7, 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 27 – 31, 2018

Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 27 – 31, 2018:

August 27, 2018: The IRS announced changes to its Compliance Assurance Process (CAP) program. We posted about the changes to CAP here.

August 28, 2018: In Notice 2018-70, the IRS announced that it will issue proposed regulations clarifying the definition of a “qualifying relative” for various purposes, including the new $500 credit for certain dependents.

August 30, 2018: The Office of Management and Budget (OMB) completed its review of a proposal to remove parts of the Internal Revenue Code Section 385 regulations, which address the treatment of debt among members of an expanded affiliated group.

August 31, 2018: The IRS released Revenue Procedure 2018-58, which includes the current list of jurisdictions subject to reporting requirements for certain deposit interest paid to nonresident alien individuals.

August 31, 2018: The IRS published statistics regarding US source income payments to foreign persons reported on Form 1042-S.

August 31, 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.




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