US IRS to issue S corporation regs reflecting international tax changes

September 2, 2020 Americas, More News, United States

The US IRS on Tuesday announced in Notice 2020-69 that it intends to issue tax regulations addressing the application of §§ 951 and 951A to S corporations with accumulated earnings and profits.

The IRS said it will also issue regulations addressing the treatment of qualified improvement property (QIP) under the alternative depreciation system of § 168(g) for purposes of calculating qualified business asset investment (QBAI) under the foreign-derived intangible income and global intangible low-taxed income rules, added in the 2017 Tax Cuts and Jobs Act.

The IRS said that it expects that forthcoming QIP and QBAI regulations under §§ 250 and 951A will clarify that a technical amendment to § 168 enacted in § 2307(a) of the CARES Act applies to determine the adjusted basis of property under § 951A(d)(3) as if it had been enacted as part of § 13204 of the 2017 Tax Cuts and Jobs Act. The government said that it has determined that this clarification is consistent with congressional intent.

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