Weekly Report from Washington, D.C.

During the week of December 17, President Donald Trump said that he will not sign a Senate-approved stopgap spending bill to avert a government shutdown at midnight on December 21. The House approved a broad, catch-all tax and IRS oversight package. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) requested comments regarding reports of foreign financial accounts regulations and Form 114, Report of Foreign Bank And Financial Accounts (FBAR). The IRS released proposed regulations that provide guidance under Code Sec. 864(c)(8) on the transfer by foreign persons of interests in a partnership that is engaged in the conduct of a trade or business in the United States.

White House

President Donald Trump said that he will not sign a Senate-approved stopgap spending bill to avert a government shutdown at midnight on December 21, (TAXDAY, 2018/12/21, W.1).

Congress

The House approved a broad, catch-all tax and IRS oversight package, (TAXDAY, 2018/12/21, C.1).

The House Rules Committee was scheduled to consider on December 19 the third version of a GOP-led tax and IRS oversight package, (TAXDAY, 2018/12/19, C.1).

Treasury

Comment Request. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) requested comments regarding reports of foreign financial accounts regulations and Form 114, Report of Foreign Bank And Financial Accounts (FBAR), (TAXDAY, 2018/12/20, T.1).

IRS

Regulation. The IRS released proposed regulations that provide guidance under Code Sec. 864(c)(8) on the transfer by foreign persons of interests in a partnership that is engaged in the conduct of a trade or business in the United States, (NPRM REG-113604-18; TAXDAY, 2018/12/21, I.1).

Regulation. The IRS issued proposed regulations under several provisions to address certain hybrid arrangements, (NPRM REG-104352-18; TAXDAY, 2018/12/21, I.2).

Revenue Procedure. The IRS updated its guidance on how to make an adequate disclosure on an income tax return, (Rev. Proc. 2019-9; TAXDAY, 2018/12/21, I.3).

Notice. The IRS informed taxpayers that the Treasury Department and the IRS intend to propose regulations addressing certain special enforcement matters under Code Sec. 6241(11), (Notice 2019-6; TAXDAY, 2018/12/21, I.4).

Delegation Order. The IRS commissioner issued a delegation order delegating an authority regarding retroactive plan amendments, (TAXDAY, 2018/12/21, I.5).

Comment Request. The IRS requested comments on various forms, (TAXDAY, 2018/12/21, I.6).

Tax Tip. The IRS highlighted new online resources developed to help small businesses understand tax reform, (TAXDAY, 2018/12/21, I.7).

Notice. The IRS provided another extension of the temporary dyed fuel relief provided in section 3.02 of Notice 2017-30, 2017-21 I.R.B. 1248 (TAXDAY, 2017/05/04, I.2), (Notice 2019-4; TAXDAY, 2018/12/20, I.1).

Revenue Procedure. The IRS provided insurance companies with guidance that prescribes the unpaid loss discount factors and salvage discount factors for the 2018 accident year for use in the first tax year beginning after December 31, 2017, (Rev. Proc. 2019-6; TAXDAY, 2018/12/20, I.2).

Tax Transcript Faxing Service. The IRS announced that it would stop its tax transcript faxing service starting February 4, 2019, and offer a more secure alternative to taxpayers and tax professionals, (IR-2018-256; FS-2018-20; FS-2018-21; TAXDAY, 2018/12/20, I.3).

Revenue Ruling. The IRS provided various prescribed rates for federal income tax purposes for January 2019, (Rev. Rul. 2019-3; TAXDAY, 2018/12/20, I.4).

Business Loss Limitations. The IRS issued guidance on excess business loss limitations and net operating losses (NOLs) following law changes in the Tax Cuts and Jobs Act (TCJA), (IR-2018-254; TAXDAY, 2018/12/20, I.5).

Timely Payment of Taxes. The IRS advised employees whose 2018 federal income tax withholding unexpectedly falls short of their tax liability for the year that they could still avoid a tax-time surprise by making a quarterly estimated tax payment directly to the IRS, (IR-2018-255; TAXDAY, 2018/12/20, I.6).

Tax Tip. The IRS released informative videos about tax reform, (TAXDAY, 2018/12/20, I.7).

FAQs. The IRS issued Frequently Asked Questions (FAQs) on the Code Sec. 965 transition tax, (TAXDAY, 2018/12/19, I.1).

PMTA. PMTA discussed taxability of market facilitation program payments, (TAXDAY, 2018/12/19, I.3).

Tax Tip. The IRS urged individuals to visit its website for tax reform related queries, (TAXDAY, 2018/12/19, I.4).

Phishing Emails. The IRS warned tax professionals and employers to watch out for phishing emails involving payroll direct deposit and wire transfer scams, (IR-2018-253; TAXDAY, 2018/12/18, I.1).

Comment Request. The IRS requested comments on various procedures and Form 8586, (TAXDAY, 2018/12/18, I.2).

Tax Tip. The IRS announced that businesses can obtain tax reform information from its website, (TAXDAY, 2018/12/18, I.3).

Notice. The IRS and the Treasury intended to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP), (Notice 2019-1; TAXDAY, 2018/12/17, I.1).

Standard Mileage Rates. The IRS released the optional standard mileage rates for 2019, (IR-2018-251; Notice 2019-2; TAXDAY, 2018/12/17, I.2).

Notice. The IRS released the applicable dollar amounts under Code Sec. 45Q(b)(1) for purposes of determining the credit for carbon oxide sequestration under Code Sec. 45Q(a)(3) and Code Sec. 45Q(a)(4), (Notice 2018-93; TAXDAY, 2018/12/17, I.3).

Notice. The IRS announced that the credit for all new qualified plug-in electric drive motor vehicles sold by Tesla, Inc. will begin to phase out January 1, 2019, (Notice 2018-96; IR-2018-252; TAXDAY, 2018/12/17, I.4).

Notice. The IRS released pension plan liability rates for December 2018, (Notice 2019-3; TAXDAY, 2018/12/17, I.5).

I.R.B. The IRS released I.R.B. 2018-51, dated December 17, 2018, (TAXDAY, 2018/12/17, I.6).

Regulation. The IRS issued corrections to final regulations related to guidance concerning the scope of preparer due diligence penalty, (T.D. 9842, I.R.B. 2018-48, 783, (T.D. 9842; TAXDAY, 2018/12/17, I.7).

FAQs. The IRS updated FAQs on return filing and payment obligations, (TAXDAY, 2018/12/17, I.8).

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CCHTaxGroup

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