Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 30, 2021 – September 3, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 30, 2021: With September being National Preparedness Month, the IRS reminded everyone to develop an emergency preparedness plan—especially with the height of hurricane season approaching and the ongoing wildfires. To prepare, taxpayers should secure and duplicate essential tax and financial documents.

August 31, 2021: The IRS postponed various tax filing and payment deadlines for victims of Hurricane Ida. Affected individuals and businesses will have until January 3, 2022, to file returns and pay any taxes that were originally due during this period. This means individuals who had a valid extension to file their 2020 return due to run out on October 15, 2021, will now have until January 3, 2022, to file. However, tax payments related to 2020 tax returns that were due on May 17, 2021, are not eligible for this relief. This extension also applies to quarterly estimated income tax payments due on September 15, 2021.

September 1, 2021: The IRS issued a practice unit on general principles for foreign tax credits, specifically addressing foreign tax credits as changed by the Tax Cuts and Jobs Act of 2017.

September 2, 2021: The IRS issued final regulations, modifying previous regulations relating to IRS administrative proceedings, to reflect limitations that are required by the enactment of the Taxpayer First Act of 2019. The regulations implement new rules regarding the persons who may be provided books, papers, records or other data obtained pursuant to Internal Revenue Code Section 7602 for the sole purpose of providing expert evaluation and assistance to the IRS. The regulations adopt further limitations on the type of non-governmental attorneys to whom any books, papers, records or other data may be provided. Under the final regulations, IRS contractors are prohibited from asking substantive questions of a summoned witness under oath or asking a summoned person’s representative to clarify an objection or assertion of privilege.

September 3, 2021: The IRS issued Revenue Procedure 2021-40, announcing that it will not issue private letter rulings or determination letters on whether certain transactions are considered an act of self-dealing under Internal Revenue Code Section 4941.

September 3, 2021: The IRS issued Notice 2021-52, providing travel per diem rates for 2021 – 2022.

September 3, 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 Emily Mussio in our Chicago office for this week’s roundup.

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