Wednesday, September 9, 2020
Introduced beneath is our abstract of great Inner Income Service (IRS) steering and related tax issues for the week of August 31, 2020 – September 4, 2020.
September 1, 2020: The IRS launched for publication within the federal register ultimate rules offering extra steering on the bottom erosion and anti-abuse tax (BEAT) imposed on sure massive company taxpayers with respect to sure funds made to overseas associated events. The ultimate rules have an effect on firms with substantial gross receipts that make funds to overseas associated events.
September 1, 2020: The IRS introduced the launch of the Bipartisan Funds Act (BBA) Centralized Partnership Audit Regime webpage. The Centralized Partnership Audit Regime replaces the Tax Fairness and Fiscal Duty Act (TEFRA) and the electing massive partnership guidelines. The centralized partnership audit regime, or BBA, is usually efficient for tax years starting January 2018. Below the BBA, the IRS typically assesses and collects any understatement of tax (known as an imputed underpayment) on the partnership stage.
September 1, 2020: The IRS printed a memorandum offering steering on the Bipartisan Funds Act of 2015 (BBA) till Inner Income Handbook (IRM) 8.19 is revised. The steering covers: (1) Appeals TEFRA Workforce (ATT) and Technical Steerage (TG) referrals; (2) Tax Courtroom guidelines on BBA partnership proceedings; (3) Tax Computation Specialist (TCS) help; (4) Tried Instances and Counsel Settlements; (5) Tax Courtroom Determination Appealed and Remaining Determination from Attraction; and (6) Division of Justice (DOJ) instances.
September 1, 2020: The IRS introduced its intention to challenge rules addressing the applying of sections 951 and 951A of the Inner Income Code (Code) to sure S firms (as outlined in part 1361(a)(1)) with accrued earnings and earnings, as described in part 316(a)(1) (AE&P). The discover additionally pronounces that the US Division of the Treasury and the IRS intend to challenge rules addressing the remedy of certified enchancment property (QIP) below the choice depreciation system (ADS) of part 168(g) for functions of calculating certified enterprise asset funding (QBAI) for functions of the foreign-derived intangible revenue (FDII) and international intangible low-taxed revenue (GILTI) provisions. Feedback ought to be submitted by November 2, 2020.
September 1, 2020: The IRS requested feedback on Income Process 2015-40 (that gives steering for taxpayers who imagine that the actions of the US, a treaty nation or each consequence or will lead to taxation that’s opposite to the provisions of an relevant tax treaty) to submit the requested data in an effort to obtain help from the IRS official performing because the US competent authority. Feedback are due on or earlier than November 2, 2020.
September 3, 2020: The IRS launched the fourth quarter replace to the 2019–2020 Precedence Steerage Plan. The fourth quarter replace to the 2019-2020 plan displays 53 extra initiatives which have been printed (or launched) throughout the interval from April 1, 2020, via June 30, 2020. This replace additionally contains one extra challenge which was launched on March 31, 2020.
September 3, 2020: The IRS launched IRB 2020-37, dated September 8, 2020, containing the next highlights: (1) REG-116475-19 (Worker Plans); (2) Income Ruling 2020-16 (Property Tax); and (3) Income Ruling 2020-17 (Revenue Tax).
September 3, 2020: The IRS introduced that rates of interest will stay the identical for the calendar quarter starting October 1, 2020. Income Ruling 2020-18, asserting the charges of curiosity, will seem in Inner Income Bulletin 2020-39, dated September 21, 2020.
September 4, 2020: The IRS launched for future publication within the federal register on September 14, 2020 ultimate rules offering steering in regards to the limitation on the deduction for enterprise curiosity expense after modification of the Code by the Tax Cuts and Jobs Act (TCJA) and the Coronavirus Support, Aid and Financial Safety Act (CARES Act). The rules present steering to taxpayers on how one can calculate the limitation, what constitutes curiosity for functions of the limitation, which taxpayers and trades or companies are topic to the limitation and the way the limitation applies in consolidated group, partnership, worldwide and different contexts.
September 4, 2020: The IRS printed a discover of proposed rulemaking in regards to the limitation on the deduction for enterprise curiosity expense after modification of the Code by the TCJA and CARES Act. Feedback are due by November 2, 2020.
September 4, 2020: The IRS launched its weekly listing of written determinations (e.g., Personal Letter Rulings, Technical Recommendation Memorandums and Chief Counsel Recommendation).
Particular due to Robbie Alipour in our Chicago workplace for this week’s roundup.