The US IRS on August 15 released its list of priority tax guidance projects for 2016-17, revealing that the agency has decided to work on issuing guidance in the areas of foreign currency contracts and country-by-country reporting.
The IRS’s annual list of priority tax guidance contains 281 projects that the agency has decided are priorities for the allocation of resources from July 2016– June 2017.
Most of the 37 international tax projects on the list have carried over from last year’s priority guidance list.
New this year, though, is a project to issue regulations under section 1256(g)(2) regarding the definition of a foreign currency contract. The guidance will reflect the decision in Wright v. Commissioner, 809 F.3d 877 (6th Cir. 2016), the Service said.
Also new on the international tax list is a project to issue guidance on the procedures for US parented multinationals to voluntarily file with the IRS country-by-country reports for taxable years beginning on or after January 1, 2016, but before the effective date of the final country-by-country reporting regulations.
The IRS had previously announced its intention to issue such guidance when it issued the final country-by-country reporting regulations last June.
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