Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 10 – 14, 2018:
September 10, 2018: The IRS announced the following five new Large Business & International compliance campaigns: (1) Internal Revenue Code (Code) Section 199 Claims Risk Review; (2) Syndicated Conservation Easement Transactions; (3) Foreign Base Company Sales Income: Manufacturing Branch Rules; (4) Form 1120F Interest Expense/Home Office Expense; and (5) Individuals Employed by Foreign Governments and International Organizations. We discuss these new campaigns in more detail here and have reported about previous LB&I campaigns in the below blog posts.
September 13, 2018: Treasury and the IRS released proposed regulations under Code Section 951A, the new tax on global intangible low-taxed income earned by controlled foreign corporations. The proposed regulations include a number of anti-abuse provisions.
September 13, 2018: The IRS published Revenue Procedure 2018-48, which provides guidance regarding how certain amounts included in income under Code Sections 951(a)(1) and 986(c) are treated for purposes of determining whether a REIT satisfies the Code Section 856(c)(2) gross income test.
September 14, 2018: The IRS issued Notice 2018-73, which provides updated interests rates and guidance regarding the corporate bond monthly yield curve.
September 14, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).
