The US IRS on February 7 released the second quarter update to its 2017–2018 Priority Guidance Plan, which lists the tax guidance the agency hopes to complete in the coming year.
The updated plan includes 18 new entries describing guidance needed to implement the Tax Cuts and Jobs Act (TCJA), including “guidance implementing new section 965 and other international sections of the TCJA” and clarification of the new limitation on the deductibility of business interest expense under section 163(j).
The IRS added to its priority list a new project to craft regulations and other guidance under section 861 regarding the allocation and apportionment of interest expense, including guidance related to interest expense attributable to loans to related partnerships.
A second project under section 861, carried over from the previous quarterly update, would address the character of income, including income arising in transactions involving intellectual property and the provision of digital goods and services.
Still on the list is a project to modify regulations under section 367 regarding the treatment of transfers of property to foreign corporations. This project was added as part of the administration’s pledge to identify and reduce regulatory burdens.
The full list of priority tax guidance to implement the TCJA is as follows:
- Guidance on certain issues related to the business credit under section 45S with respect to wages paid to qualifying employees during family and medical leave
- Guidance under sections 101 and 1016 and new section 6050Y regarding reportable policy sales of life insurance contracts
- Guidance under section 162(m) regarding the application of the effective date provisions to the elimination of the exceptions for commissions and performance-based compensation from the definition of compensation subject to the deduction limit
- Guidance under section 162(f) and new section 6050X
- Computational, definitional, and other guidance under new section 163(j)
- Guidance on new section 168(k)
- Computational, definitional, and anti-avoidance guidance under new section 199A
- Guidance adopting new small business accounting method changes under sections 263A, 448, 460, and 471
- Definitional and other guidance under new section 451(b) and (c)
- Guidance on computation of unrelated business taxable income for separate trades or businesses under new section 512(a)(6)
- Guidance implementing changes to section 529
- Guidance implementing new section 965 and other international sections of the new tax law (Notice 2018-07, released December 29, 2017)
- Guidance implementing changes to section 1361 regarding electing small business trusts
- Guidance regarding Opportunity Zones under sections 1400Z–1 and 1400Z–2
- Guidance under new section 1446(f) for dispositions of certain partnership interests (Notice 2018-08, released December 29, 2017)
- Guidance on computation of estate and gift taxes to reflect changes in the basic exclusion amount
- Guidance regarding withholding under sections 3402 and 3405 and optional flat rate withholding
- Guidance on certain issues relating to the excise tax on excess remuneration paid by “applicable tax-exempt organizations” under section 4960
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