Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 29 – August 2, 2019.
July 30, 2019: The IRS issued a list of answers to frequently asked questions in which it addressed questions regarding basis adjustments and the 50% of gross income test in the context of investments in Opportunity Zones as governed provided for within Section 1400Z-2.
July 31, 2019: The IRS issued a news release noting that it has issued a revenue procedure allowing a taxpayer to make a late election, or to revoke an election, for bonus depreciation under section 168(k) for certain property acquired by the taxpayer after September 27, 2017, and placed in service by the taxpayer during its taxable year that includes September 28, 2017.
August 1, 2019: The IRS issued amendments to the preamble for regulations issued to limit the charitable contribution deduction when receiving state and local tax credits. The correction was made by updating an Internal Revenue Bulletin citation for Notice 2019-12 to include the page number after the official publication. The notice provides a safe harbor for individuals who itemize deductions and makes a payment to a tax code Section 170(c) entity in return for a state or local tax credit to treat the portion of such payment that is or will be disallowed as a charitable contribution deduction under Section 170 as a payment of state or local tax for purposes of Section 164.
August 1, 2019: The IRS released proposed regulations providing corrections to previously issued proposed rules under tax code Section 958 (providing proposed regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations) and under Section 951A (providing proposed regulations under GILTI provision 1.951A-2 regarding income subject to a high rate of foreign tax).
August 2, 2019: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).