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Tag Archive for IRS Notice

IRS Finalizes Regulations For 100 percent Bonus Depreciation

IRS Finalizes Regulations For 100 percent Bonus Depreciation

The Treasury Department and the Internal Revenue Service released the last set of final regulations implementing the 100% additional first year depreciation deduction that allows businesses to write off the cost of most depreciable business assets in the year they are placed in service by the business.

The 100% additional first year depreciation deduction was created in 2017 by the Tax Cuts and Jobs Act and generally applies to depreciable business assets with a recovery period of 20 years or less and certain other property. Machinery, equipment, computers, appliances and furniture generally qualify.

The deduction applies to qualifying property (including used property) acquired and placed in service after Sept. 27, 2017. The final regulations provide clarifying guidance on the requirements that must be met for property to qualify for the deduction, including used property.

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IRS Reminds Taxpayers And Practitioners Of Expedited Letter Ruling Procedures

IRS Reminds Taxpayers And Practitioners Of Expedited Letter Ruling Procedures

The Internal Revenue Service continues to look for ways to assist taxpayers affected by the COVID-19 pandemic.  As part of that effort, the IRS reminds taxpayers and tax practitioners of the procedures for requesting expedited handling of requests for letter rulings under Rev. Proc. 2020-1, 2020-1 I.R.B. 1 (Jan. 2, 2020).

As set forth in Rev. Proc. 2020-1, the IRS ordinarily processes requests for letter rulings in the order that they were received.  A taxpayer with a compelling need to have a request processed more quickly may request expedited handling.  The request for expedited handling must be made in writing, preferably in a separate letter submitted with the letter ruling request.  Requests for expedited handling are granted at the discretion of the IRS and typically involve a factor outside of the taxpayer’s control that creates a real business need to obtain a letter ruling before a certain date in order to avoid serious business consequences.  Requests for expedited handling should be submitted as promptly as possible after the taxpayer has become aware of the deadline or compelling business need. 

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IRS Updates LB&I Examination Directive On Credit For Increasing Research Activities

IRS Updates LB&I Examination Directive On Credit For Increasing Research Activities

The IRS has revised guidance for examiners in the Large Business & International division (LB&I) reviewing the amounts claimed for the tax credit for increasing research activities.

The guidance to auditors issued today modifies a directive issued in 2017. The credit for increasing research activities (Internal Revenue Code § 41) enables taxpayers to receive a tax credit for qualified research activities (QREs).

Independently determining the correct amount of this research credit claimed by large corporate taxpayers can be resource intensive for those taxpayers and IRS examiners. This revised directive provides an efficient methodology for determining QREs for these taxpayers that meet the requirements of the updated directive.

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Final Regulations On Business Interest Expense Deduction Limitation Published In The Federal Register

Final Regulations On Business Interest Expense Deduction Limitation Published In The Federal Register

The final regulations for the business interest expense deduction limitation published in the Federal Register today. The final regulations vary slightly from the document released on IRS.gov on July 28, 2020.

The Treasury Department and the IRS released a version of the final regulations on the business interest expense deduction limitation on IRS.gov on July 28, 2020. The version released on IRS.gov contains a disclaimer that the document had been submitted to the Office of the Federal Register for publication, and notes that the version of the final regulations may vary slightly from the document published in the Federal Register.

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IRS To Mail Special Letter To Estimated 9 Million Non-Filers, Urging Them To Claim Economic Impact Payment By Oct. 15

IRS To Mail Special Letter To Estimated 9 Million Non-Filers, Urging Them To Claim Economic Impact Payment By Oct. 15

Later this month, the Internal Revenue Service will start mailing letters to roughly 9 million Americans who typically don’t file federal income tax returns who may be eligible for, but have not registered to claim, an Economic Impact Payment. 

The letters will urge recipients to register at IRS.gov by Oct. 15 in order to receive their payment by the end of the year. Individuals can receive up to $1,200, and married couples can receive up to $2,400. People with qualifying children under age 17 at the end of 2019 can get up to an additional $500 for each qualifying child.

The letters are being sent to people who haven’t filed a return for either 2018 or 2019. Based on an internal analysis, these are people who don’t typically have a tax return filing requirement because they appear to have very low incomes, based on Forms W-2, 1099s and other third-party statements available to the IRS. But many in this group are still eligible to receive an Economic Impact Payment.

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IRS Launches BBA Centralized Partnership Audit Webpage

IRS Launches BBA Centralized Partnership Audit Webpage

The IRS announces the launch of the Bi-Partisan 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 audit regime, or BBA, is generally effective for tax years beginning January 2018. Under the BBA, the IRS generally assesses and collects any understatement of tax (called an imputed underpayment) at the partnership level.

A partnership is subject to BBA unless it is an eligible partnership and makes an annual election out of BBA on a timely filed Form 1065. An eligible partnership is one with 100 or fewer partners, all of whom are either individuals, C corporations, foreign entities that would be treated as a C corporation if it were domestic, S corporations or estates of deceased partners.

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Earning Side Income: Is it A Hobby Or A Business?

Earning Side Income: Is it A Hobby Or A Business?

Whether it’s something they’ve been doing for years or something they just started to make extra money, taxpayers must report income earned from hobbies in 2020 on next year’s tax return.

What the difference between a hobby and a business? A business operates to make a profit. People engage in a hobby for sport or recreation, not to make a profit.

Here are nine things taxpayers must consider when determining if an activity is a hobby or a business:

  • Whether the activity is carried out in a businesslike manner and the taxpayer maintains complete and accurate books and records.
  • Whether the time and effort the taxpayer puts into the activity show they intend to make it profitable.
  • Whether they depend on income from the activity for their livelihood.
  • Whether any losses are due to circumstances beyond the taxpayer’s control or are normal for the startup phase of their type of business.
  • Whether they change methods of operation to improve profitability.
  • Whether the taxpayer and their advisors have the knowledge needed to carry out the activity as a successful business.
  • Whether the taxpayer was successful in making a profit in similar activities in the past.
  • Whether the activity makes a profit in some years and how much profit it makes.
  • Whether the taxpayers can expect to make a future profit from the appreciation of the assets used in the activity.

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Treasury And IRS Release Draft Partnership Form To Provide Greater Clarity On International Tax Reporting

IRS Notice

The Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The proposed form is designed to provide greater clarity for partners on how to compute their U.S. income tax liability with respect to items of international tax relevance, including claiming deductions and credits.

The redesigned form and instructions provide guidance to partnerships on how to report international tax information to their partners in a standardized format. This proposed form would apply to a partnership required to file Form 1065 only if the partnership has items of international tax relevance (generally foreign activities or foreign partners). The proposed changes would not affect domestic partnerships with no international tax items to report.

This early release is intended to afford time for stakeholder input and engagement. Treasury and IRS invite comments from affected stakeholders through Sept. 14, 2020. Written comments should be sent to the following email address: lbi.passthrough.international.form.changes@irs.gov with the subject line: “International Form Changes.”
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Major Changes To Retirement Plans Due To COVID-19

Major Changes To Retirement Plans Due To COVID-19

Qualified individuals affected by COVID-19 may be able to withdraw up to $100,000 from their eligible retirement plans, including IRAs, between Jan. 1 and Dec. 30, 2020.

These coronavirus-related distributions aren’t subject to the 10% additional tax that generally applies to distributions made before reaching age 59 and a half, but they are still subject to regular tax. Taxpayers can include coronavirus-related distributions as income on tax returns over a three-year period. They must repay the distribution to a plan or IRA within three years.

Some plans may have relaxed rules on plan loan amounts and repayment terms. The limit on loans made between March 27 and Sept. 22, 2020 is raised to $100,000. Plans may suspend loan repayments due between March 27 and Dec. 31, 2020.
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IRS Finalizes Guidance On Deduction For Foreign-Derived Intangible Income And Global Intangible Low-Taxed Income

IRS Finalizes Guidance On Deduction For Foreign-Derived Intangible Income And Global Intangible Low-Taxed Income

The Internal Revenue Service issued final regulations that provide guidance on deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income allowed to domestic corporations under the Internal Revenue Code.

These final regulations provide guidance on both the computation of the deductions available and the determination of FDII.

In addition, the guidance provides rules for the computation of FDII in the consolidated return context.

The guidance published today also finalizes the reporting rules requiring the filing of Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income.

For more information about this and other Tax Cuts and Jobs Act provisions, visit IRS.gov/taxreform.

The Postponed Federal Tax Deadline Applies To Taxpayers Living Overseas

The Postponed Federal Tax Deadline Applies To Taxpayers Living Overseas

Taxpayers who live and work abroad have until Wednesday, July 15, 2020 to file and pay their 2019 federal income taxes.

U.S. citizens and resident aliens generally have the same filing and payment requirements regardless of where they live. The July 15 postponed deadline also applies to nonresident aliens and foreign entities with a U.S. filing and payment requirement.

Taxpayers who still owe 2019 income tax, as well as estimated tax for 2020, must make two separate payments on or by July 15, 2020: One for their 2019 income taxes owed and one for their 2020 estimated tax payments. The two estimated tax payments can be combined into a single payment.
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