Weekly IRS Roundup March 18 – 22, 2019

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 March 18 – 22, 2019.

March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on proposed regulations on hybrid arrangements under Sections 245A and 267A of the code.

March 19, 2019: The IRS issued Revenue Procedure 2019-14 providing issuers of qualified mortgage bonds and issuers of mortgage credit certificates the nationwide average purchase price for residences located in the United States, and the average area purchase price safe harbors for residences located in certain statistical areas.

March 20, 2019: The IRS requested comments on the treatment of distributions by foreign corporations and coordination with nonrecognition provisions. Comments should be received by May 20, 2019.

March 20, 2019: The IRS issued a news release announcing the conclusion of what it refers to as the “dirty dozen” list of tax scams.

March 21, 2019: The IRS issued Revenue Ruling 2019-09 suspending two revenue rulings from 1957 pending the completion of a study regarding the active trade or business requirement under Sections 355(a)(1)(C) and (b) of the code.

March 22, 2019: The IRS issued Proposed Regulations on new information reporting requirements for certain life insurance companies under Section 6050Y of the code.

March 22, 2019: The IRS issued Notice 2019-25 modifying and superseding Notice 2019-11. The notice increases the availability of the waiver of the addition to tax for underpayment of estimated income tax for certain individuals for 2018.

March 22, 2019: The IRS issued Notice 2019-26 updating mortality improvement rates and static mortality tables for determining the minimum funding requirements under § 430(h)(3) for 2020. The notice also updates the minimum present value under § 417(e)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2020 calendar year.

Special thanks to Terence McAllister in our New York office for this week’s roundup.

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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