Senate Introduces Substitute Amendment: Today, the Senate released an amendment in the nature of a substitute to the Tax Cuts and Jobs Act (H.R. 1). The amendment adds Title II, a provision permitting oil drilling in Alaska.

Joint Committee on Taxation Releases Economic Analysis of Senate Tax Proposal: The Joint Committee on Taxation (JCT) today released its dynamic score of the Senate’s tax proposal. The JCT found that the proposal would generate economic growth of $458 billion to lower the proposal’s $1.4 trillion estimated revenue cost. The economic growth would be offset by $50 billion increased interest payments.

IRS Expands Penalty-Abatement Relief for Taxpayers Affected by Changes to Partnership Return Filing Due Dates: Today, the IRS issued Notice 2017-71, which extends penalty abatement relief to a much broader class of filing, payment, and election actions that occurred in 2016 tax years tied to partnership return filing due dates, including real estate mortgage investment conduit (REMIC) elections, section 475 mark-to-market elections, common trust fund filings, qualified electing fund (QEF) elections, purging elections, employee benefit plan contributions by employers, excise tax payments regarding employer-provided group health care, and mixed straddle account elections. The IRS previously offered relief for abating failure-to-file penalties for partnerships and REMICs for 2016 tax years who otherwise met such requirements before the changes enacted in the 2015 Surface Transportation Act. The Surface Transportation Act moved the due date for partnership tax returns up a month, from the 15th day of the 4th month to the 15th day of the 3rd month following the end of the taxable year.

OECD Releases Further Guidance for Country-by-Country Reporting: Today, the Organization for Economic Cooperation and Development (OECD) released additional country-by-county reporting guidance for multinational groups and tax administrators. The guidance addresses a number of specific issues, including how to report amounts taken from fair-value financial statements; how to treat mergers, acquisitions, and de-mergers; how to treat short accounting periods; and the definition of total consolidated group revenue.