e-News for Tax Professionals Issue 2020-32

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Issue Number:  2020-32

Inside This Issue

1. IRS Nationwide Tax Forums: Upcoming seminars for Aug. 11-13
2. Working Virtually, Part 3: Use a virtual private network to secure remote locations
3. Small Business Division issues annual report
4. James Lee selected to lead IRS Criminal Investigation
5. Aug. 13 Webinar: Understanding the e-Services Transcript Delivery System
6. Webinar: Proposed International Changes to Form 1065, U.S. Return of Partnership Income
7. Carried Interest: TCJA made changes to the holding period for carried interest
8. Updated FAQs: Deferral of employment tax deposits and payments through Dec. 31
9. Reminder: Work Opportunity Tax Credit Extended
10. News from the Justice Department’s Tax Division
11. Technical Guidance

The IRS Nationwide Tax Forums continue Aug. 11-13 with six seminars. The week’s offerings include “Tax Cuts and Jobs Act Update: Opportunity Zones,” “QBI Problems? We Have Solutions?” presented by the National Association of Enrolled Agents, and “Update from the IRS Independent Office of Appeals.”

The full schedule is available on IRSTaxForum.com. The online Nationwide Tax Forums continue through Aug. 20.

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As more tax professionals are teleworking during COVID-19, the IRS and the Security Summit partners urge practitioners to secure remote locations by using a virtual private network (VPN) to protect against cyber intruders.

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The IRS Small Business/Self Employed division today released a new annual report covering fiscal year 2019. The report focuses on program highlights, priorities and accomplishments of the SB/SE organization and its employees. The SB/SE Annual Report provides a 28-page overview of one of the largest IRS organizations and includes enforcement priorities including virtual currency and other topics.

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The Internal Revenue Service announced that James Lee will become the new chief of IRS Criminal Investigation (CI) on October 1.

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The IRS will present the webinar, Understanding the e-Services Transcript Delivery System, at 1 p.m. ET on Aug. 13. The 75-minute webinar will consider:

• Ensuring access to Transcript Delivery System (TDS) using e-Services
• How Secure Access Helps
• Secure Access Registration Steps for new and existing e-Services users
• How to access e-file application from IRS.gov
• Transcript Delivery System (TDS) Access for Circular 230 Tax Practitioners
• Retrieving Transcripts Provided by Practitioner Priority Service (PPS)
• Plus a Q & A session

Tax Pros can earn one continuing education credit for participating.

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Leaders from the American Bar Association, American Institute of Certified Public Accountants, the Tax Executives Institute and the IRS will participate in two upcoming webinars to provide an overview of the new Form 1065, U.S. Return of Partnership Income.

Aug. 12 Webinar – 11 AM ET – CPE Eligible
The outbound (generally) components of the new forms:

• Foreign tax credit
• Subpart F income
• Global intangible low-taxed income
• Passive foreign investment company income
• Foreign-derived intangible income
• Distributions from foreign corporations to the partnership
• Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities
 
Aug. 18 Webinar – 1 pm ET – No CPE
The inbound (generally) components of the new forms:

• Base Erosion Anti-Abuse Tax
• Income effectively connected with a U.S. trade or business
• Fixed, determinable, annual, periodical income
• Gain or loss of foreign persons from sale or exchange of certain partnership interests
• Treatment of dividend equivalent payments

Treasury and IRS invite comments from stakeholders through Sept. 14, regarding proposed updates to the partnership form for tax year 2021.

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The Tax Cuts and Jobs Act (TCJA) added section 1061, which requires partnership interest derived from the performance of investment services (carried interest) be held for more than three years to be treated as long-term capital gains. For more information, please see the proposed regulations and the Comparison of changes to rules for carried interest under TCJA, on the application of Section 1061.

The three-year holding period is required for sales of assets held (directly or indirectly) by the partnership. The three-year holding period also applies to the sale of the partnership interest itself.

Updates on this and other TCJA provisions can be found on the Tax Reform page of IRS.gov.

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The Coronavirus, Aid, Relief and Economic Security Act (CARES Act) allows employers to defer the deposit and payment of the employer's share of Social Security taxes and self-employed individuals to defer payment of certain self-employment taxes. These FAQs address specific issues related to the deferral of deposit and payment of these employment taxes.

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The Work Opportunity Tax Credit is a valuable tax credit available to employers who hire long-term unemployment recipients and others certified by their state workforce agency if the individual began or begins work for the employer after Dec. 31, 2014 and before Jan. 1, 2021.

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A federal grand jury in Chicago returned a superseding indictment this week charging the owner of a tax preparation business with filing tax returns for herself and her clients. Meanwhile, a Houston attorney was sentenced to 24 months in prison for conspiring to defraud the United States and tax evasion.

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Notice 2020-61 provides guidance regarding the special rules relating to single-employer defined benefit pension plans under section 3608 of the CARES Act.

Notice 2020-62 modifies the two model notices in Notice 2018-74, that may be provided to recipients of eligible rollover distributions to satisfy the notice requirements under section 402(f).

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