Senate Votes to Begin Debate on House Tax Reform Bill: Today, the Senate voted 52 to 48 to proceed with consideration of the Tax Cuts and Jobs Act.
IRS Proposes Limited Initial Set of Regulations for Coordination of Partnership Audit Rules With Certain International Rules: Today the Internal Revenue Service proposed regulations addressing how certain international rules operate in the context of the centralized partnership audit regime, including rules relating to the withholding of tax on foreign persons, withholding of tax to enforce reporting on certain foreign accounts, and the treatment of creditable foreign tax expenditures of a partnership. Several other issues were merely identified in the preamble with no companion regulatory text, such as changes to the amount of creditable foreign taxes under section 905(c), adjustments to deemed paid foreign taxes computed with respect to stock owned by a partnership, expanding the class of modifications to imputed underpayments to include tax rate reductions under treaties, the portfolio interest exemption, and US source capital gains, and to ensure that section 6226 push-out election adjustments to a partner that is a controlled foreign corporation are taken into account by the relevant US shareholders. The preamble implied that, after additional practitioner comments are received, these and other issues would be addressed in a subsequent set of proposed regulations.
Judge Orders Coinbase Inc. to Provide Customer Records to IRS: The US District Court for the Northern District of California ordered Coinbase Inc. to turn over to the Internal Revenue Service a portion of the records that it had sought. The records to be turned over for accounts having at least the equivalent of $20,000 in any one transaction type (buy, sell, send, or receive) in any one year during the 2013 to 2015 period are (1) the taxpayer ID number, (2) name, (3) birth date, (4) address, (5) records of account activity including transaction logs or other records identifying the date, amount, and type of transaction (purchase/sale/exchange), the post transaction balance, and the names of counterparties to the transaction, and (6) all periodic statements of account or invoices (or the equivalent).