Weekly IRS Roundup December 14 – December 18, 2020

McDermott Will & Emery

McDermott Will & Emery

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, dated December 21, 2020, containing the following highlights: Rev. Rul. 2020-81 (Administrative); TD 9912 (Administrative); TD 9933 (Exempt Organizations); TD 9934 (Income Tax); TD 9935 (Income Tax).

December 18, 2020: The IRS released Practice Units on “Determining Liability Allocations” and “Recourse vs. Nonrecourse Liabilities” relating to partnership audits.

December 18, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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