Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019.
June 4, 2019: The IRS issued a news release noting that it granted tax relief to victims of severe storms, tornadoes, straight-line winds and flooding in Oklahoma by postponing until September 16, 2019, various tax return filing and tax payment deadlines that occurred starting on May 7— including quarterly estimated tax payments due on June 17 and employment and excise tax returns due on July 31.
June 4, 2019: The IRS released issued a news release announcing that it will stop its tax transcript faxing service in June and will amend the Form 4506 series to end third-party mailing of tax returns and transcripts in July as part of its efforts to protect taxpayers from identity thieves.
June 5, 2019: The IRS released issued a news release announcing a decrease in interest rates for the third calendar quarter beginning July 1, 2019.
June 5, 2019: The IRS, in a memorandum dated May 21, 2019, indicated that it was withdrawing Directive LB&I 04-0018-004, Reasonably Anticipated Benefits in Cost Sharing Arrangements, which provided instructions for examiners on transfer pricing issue selection related to reasonably anticipated benefits in cost sharing agreements.
June 7, 2019: The IRS released final regulations for Section 337(d) effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and preventing abuse of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The final regulations impose corporate-level tax on certain transactions in which property of a C corporation becomes the property of a REIT.
June 7, 2019: The IRS released proposed regulations dealing with the section 897(l) exception from taxation on gain or loss of a qualified foreign pension fund attributable to specified interests in US real property. The proposed regulations also provide rules for how to certify that a qualified foreign pension fund is not subject to withholding on some dispositions of, and distributions for, US real property interests.
June 7, 2019: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).
Special thanks to Alex Ruff in our Chicago office for this week’s roundup.