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Weekly IRS Roundup December 21 – December 26, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 21 – December 26, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. December 21, 2020: The IRS released TD 9941 containing final regulations regarding the timing of income inclusion under an accrual method of accounting, including the treatment of advance payments for goods, services and certain other items. December 22, 2020: The IRS issued Notice 21-02 providing the standard mileage rate for 2021. December 22, 2020: The IRS issued Notice 21-03 extending temporary relief from the physical presence requirement for spousal consents under certain qualified retirement plans. December 22, 2020: The IRS issued Notice 21-04 extending temporary relief for certain dyed fuel removals related to the West Shore Pipeline shutdown. December 23, 2020: The IRS released TD 9942...

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Weekly IRS Roundup December 14 – December 18, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 14 – December 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. December 14, 2020: The IRS released Notice 2020-88 updating and amplifying procedures for Phase III of the section 48A advanced coal credit. December 16, 2020: The IRS issued Revenue Ruling 21-01 providing various rates for determining the issue price of certain debt instruments issued for property. December 16, 2020: The IRS issued Notice 21-01 delaying mandatory e-filing of Form 4720 by private foundations and announcing certain other changes. December 18, 2020: The IRS released TD 9932 containing final regulations under Section 162(m) related to the employer deduction for certain employee remuneration in excess of $1 million. December 18, 2020: The IRS released Internal Revenue Bulletin 2020-52,...

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Weekly IRS Roundup November 2 – November 6, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 2, 2020 – November 6, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. November 2, 2020: The IRS announced COVID-19-related changes to tax debt collection procedures to provide taxpayer relief. November 4, 2020: The IRS released Rev. Proc. 2020-48 regarding discount factors used by insurance companies for the 2020 accident year. November 4, 2020: The IRS released Rev. Proc. 2020-49 regarding the public approval requirement for tax-exempt qualified private activity bonds. November 5, 2020: The IRS released Rev. Rul. 2020-23 related to certain distributions upon termination of a section 403(b) retirement plan. November 5, 2020: The IRS updated FAQs related to qualified intermediaries, withholding for foreign partnerships and withholding for foreign trusts. November...

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Weekly IRS Roundup October 5 – October 9, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 5, 2020 – October 9, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. October 7, 2020: The IRS published final regulations related to the withholding tax and information reporting requirements for the sale, exchange or redemption of a partnership interest held by a foreign person. October 7, 2020: The IRS published a draft of Publication 509 with draft tax calendars for 2021. October 9, 2020: The IRS published Revenue Ruling 2020-19 related to changes in basis of computing life insurance reserves. October 9, 2020: The IRS published Revenue Procedure 2020-44 to facilitate a transition from interbank offered rates to alternate reference rates. October 9, 2020: The IRS released Internal Revenue Bulletin 2020-42, dated October 13, 2020, containing the following...

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Weekly IRS Roundup September 21 – September 25, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. September 21, 2020: The IRS released Announcement 2020-12 to detail information reporting requirements for taxpayers seeking forgiveness of Paycheck Protection Program loans under the Coronavirus Aid, Relief and Economic Security (CARES) Act. September 21, 2020: The IRS published final regulations related to bonus depreciation. The rules provide additional guidance to final regulations issued in 2019. September 21, 2020: The IRS published final regulations providing guidance for certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a trade or business within the United States. September 21, 2020: The IRS published...

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Weekly IRS Roundup September 14 – September 18, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 14, 2020 – September 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. September 14, 2020: The IRS published final regulations providing guidance on the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the Tax Cuts and Jobs Act (TCJA) and the Coronavirus Aid, Relief and Economic Security Act (CARES Act). The regulations provide guidance to taxpayers on how to calculate the limitation, what constitutes interest for purposes of the limitation, which taxpayers and trades or businesses are subject to the limitation and how the limitation applies in consolidated group, partnership, international and other contexts. The final regulations vary slightly from the document released on IRS.gov on July 28,...

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Weekly IRS Roundup August 31 – September 4, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. September 1, 2020: The IRS released for publication in the federal register final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties. September 1, 2020: The IRS announced the launch of the Bipartisan Budget Act (BBA) Centralized Partnership Audit Regime webpage. The Centralized Partnership Audit Regime replaces the Tax Equity and Fiscal Responsibility Act (TEFRA) and the electing large partnership rules. The centralized partnership...

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Weekly IRS Roundup August 24 – August 28, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 24 2020: The IRS published a memorandum concerning guidance to the field on the criteria that should be applied in considering if a request for designation for litigation should be made to the Office of Chief Counsel. The memorandum also provides interim guidance on the requirements of Section 1001 of the Taxpayer First Act (TFA) with respect to the limitation on designation of cases as not eligible for referral to the IRS Independent Office of Appeals. August 25, 2020: The IRS published a Summer 2020 Statistics of Income Bulletin. The Summer 2020 Bulletin focuses individual income tax shares, 2017; foreign recipients of US income, calendar year 2017; effects of post-filing adjustments on...

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Weekly IRS Roundup August 17 – August 21, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 19, 2020: The IRS requested comments from large corporate taxpayers currently utilizing the procedures under Revenue Procedure 94-69 to disclose changes in tax positions after the opening of an examination. The IRS is considering obsoleting Revenue Procedure 94-69, which is available to a small group of large corporate taxpayers. Revenue Procedure 94-69 provides special procedures for taxpayers that are subject to the (former) Coordinated Examination Program to show additional tax due or make disclosures to avoid the imposition of accuracy-related penalties for negligence, disregard of rules or regulations or substantial understatement of income tax under sections 6662(b)(1) and (b)(2)....

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Weekly IRS Roundup August 10 – August 14, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 10, 2020: The IRS published corrections to a notice of proposed rulemaking related to section 245A(e) (Hybrid Dividends) that was published in the Federal Register on April 8, 2020. The notice contained proposed regulations that adjust hybrid deduction accounts to take into account earnings and profits of a controlled foreign corporation that are included in income by a US shareholder. The corrections are effective on August 11, 2020. August 10, 2020: The IRS published corrections to final regulations from Treasury Decision 9896 that were published in the Federal Register on Wednesday, April 8, 2020. The final regulations provide guidance regarding hybrid dividends and certain amounts paid...

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