section 355
Subscribe to section 355's Posts

Weekly IRS Roundup March 11 – 15, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4 – 8, 2019.

March 11, 2019: The IRS cancelled a public hearing scheduled for March 14 on proposed regulations on changes to the foreign tax credit under Section 904 of the Code.

March 12, 2019: The IRS issued Notice 2019-10 requesting comments on possible changes to rules regarding the excise tax treatment of fuel used in a motor vehicle to operate auxiliary equipment via a power take-off.

March 12, 2019: The IRS issued a notice listing the names of individuals losing US citizenship (within the meaning of section 877(a) or 877A) pursuant to Section 6039G of the Code.

March 12, 2019: The IRS announced that a private letter ruling pilot program addressing whether stock distributions are tax free under Section 355 would be extended indefinitely.

March 13, 2019: The IRS issued Revenue Ruling 2019-06 providing tables of covered compensation under Section 401(1)(5)(e) of the Code.

March 13, 2019: The IRS issued a news release providing information on up to $1.4 billion of unclaimed income tax refunds from 2015. The unclaimed refunds potentially affect up to 1.2 million taxpayers who did not file 2015 returns.

March 13, 2019: The IRS issued a news release detailing the rise in the use of IRS FreeFile to prepare and electronically file returns. The IRS states 1.4 million taxpayers took advantage of FreeFile as of March 8, a 5 percent increase from the same time last year.

March 14, 2019: The IRS issued Notice 2019-21 providing guidance on the corporate bond monthly yield curve, spot segment rates under Section 417(e)(3) and the 24 month average segment rates under Section 430(h)(2).

March 15, 2019: The IRS released Revenue Ruling 2019-08 providing monthly tables of prescribed rates under numerous Code sections including the applicable federal rate for April.

Special thanks to Terence McAllister in our New York office for this week’s roundup.

read more

IRS and Treasury Release Update to 2016-2017 Priority Guidance Plan

The US Department of the Treasury and Internal Revenue Service (IRS) issue Priority Guidance Plans each year to identify and prioritize the tax issues they believe should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.  On October 31, 2016, the IRS and Treasury released the first quarter update to the 2016-2017 Priority Guidance Plan originally released on August 15, 2016.

The original plan identified 281 guidance projects as priorities, and the first quarter update includes an additional six guidance projects.  The additional projects include:

  • Guidance regarding the removal of the no-rule positions for certain legal issues concerning device and business purpose under section 355 (PUBLISHED 09/12/16 in IRB 2016-37 as REV. PROC. 2016-45 (RELEASED 08/26/16)).
  • Revenue procedure providing a self-certification procedure for waivers of the 60-day rollover requirement under §§402(c)(3) and 408(d)(3) (PUBLISHED 09/12/16 in IRB 2016-37 as REV. PROC. 2016-47 (RELEASED 08/24/16)).
  • Announcement on hardship distributions and loans from retirement plans as a result of Louisiana storms (PUBLISHED 09/12/16 in IRB 2016-37 as ANN. 2016-30 (RELEASED 08/30/16)).
  • Announcement concerning the tax treatment of payments made on behalf of or reimbursements received by residents affected by the Southern California Gas Company natural gas leak (PUBLISHED 08/01/16 in IRB 2016-31 as ANN. 2016-25 (RELEASED 07/19/16)).
  • Guidance for income and employment tax purposes on the treatment of cash payments made by employers under leave-based donation programs for the relief of victims of the Louisiana storms (PUBLISHED 10/03/16 in IRB 2016-40 as NOT. 2016-55 (RELEASED 09/16/16); and
  • Guidance under §909 related to foreign-initiated adjustments and the separation of foreign taxes and related income (PUBLISHED 10/03/16 in IRB 2016-40 as NOT. 2016-52 (RELEASED 09/15/16)).

read more




jd supra readers choice top firm 2023 badge