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Weekly IRS Roundup January 20 – 24, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 20 – 24, 2020. January 20, 2020: The IRS released new Instructions to IRS Form 1120-S, US Income Tax Return for an S Corporation. These changes conform to the new regulations, which changed the qualified business income deduction, addressed qualified opportunity fund investments, and removed the AMT refundable credit. In conjunction with these changes, the IRS also released updated Instructions to Form 1065, Partner’s Share of Income, Deductions, Credits, etc., so that it complied with the new rules regarding the qualified business income deduction. January 21, 2020: The IRS issued a notice updating both the corporate bond weighted average interest rates and the permissible range of interest rates used to calculate pension plan minimum funding for plan years beginning in January 2020. The IRS updated various projections,...

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Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year 2019: (i) Form 1065, US Return of Partnership Income; (ii) its Schedule K-1, Partner’s Share of Income, Deductions, Credits, etc.; (iii) Form 1120-S, US Income Tax Return for an S Corporation; and (iv) its Schedule K-1, Shareholder’s Share of Income, Deductions, Credits, etc. The IRS intends the changes to the form and schedule to improve the quality of the information reported by partnerships both to the IRS and the partners of such entities and to improve the data available for the IRS’s compliance selection processes. This draft gives tax practitioners a preview of the changes and software providers the information they need to update systems before the final version of the updated forms and schedules are released in December. There is a...

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Tax Blog: New Questions and Answers for Section 965

The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or triggering events, and other matters related to S corporation shareholders making the section 965(i) election. Consistent with prior advice issued by the IRS (see coverage here and here), the Questions and Answers provide that the IRS cannot make a refund or apply as a credit any amount of an installment payment until the entire income tax liability is satisfied (i.e., any overpayments of an installment obligation will be used to satisfy future section 965 installment payments). The Questions and Answers also provides details on payment obligations with respect to successive installment payments under section 965(h). In particular, the IRS will “make every effort to issue an installment notice and payment voucher” for each successive...

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Weekly IRS Roundup May 6 – 10, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue Procedure 75-50 in order to reflect technological advances. Revenue Procedure 75-50 provides guidelines to determine whether a private school has adopted racially nondiscriminatory policies for tax exemption purposes. May 7, 2019: The IRS released Notice 2019-33 requesting comments regarding possible normalization issues stemming from the decrease in the corporate tax rate under Section 11 of the Code. May 7, 2019: The IRS issued a news release recognizing National Small Business Week and reminding taxpayers that a tax identification number will now be required when requesting an employer identification number. May 8, 2019: The IRS released Notice 2019-34 providing the inflation-adjusted maximum value of employer provided vehicles first made...

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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...

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Bring That CFC on Home: Domesticating Individually-Owned CFCs After Tax Reform

Several changes in tax reform have a disparate impact on non-corporate US shareholders of foreign corporations compared with their corporate counterparts. Many such non-corporate shareholders face an expensive tax increase. They may attempt to mitigate this increase by transferring their shares to a US corporation or making a Section 962 election. This article examines the new rules governing US individuals who own foreign corporations and discusses the most significant recent changes, including a lack of participation exemption for US individuals who own foreign corporations and a higher transition tax rate. It further outlines new options for domestication of such foreign corporations. Continue Reading. Originally published in Bloomberg BNA Daily Tax Report – October 26, 2018 – Number 205.

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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...

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