Internal Revenue Service January 19, 2021 – Federal Register Recent Federal Regulation Documents

Proposed Collection; Comment Request for Certain Returned Magazines, Paperbacks, or Records
Document Number: 2021-01018
Type: Notice
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning certain returned magazines, paperbacks, or records.
Proposed Collection; Comment Request for General Revision of Regulations Relating To Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons
Document Number: 2021-00954
Type: Notice
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning general revision of regulations relating to withholding of tax on certain U.S. source income paid to foreign persons.
Proposed Collection; Comment Request for Electronic Deposit of Tax Refund of $1 Million or More
Document Number: 2021-00953
Type: Notice
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning electronic deposit of tax refund of $1 million or more.
Tax on Excess Tax-Exempt Organization Executive Compensation
Document Number: 2021-00772
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document sets forth final regulations under section 4960 of the Internal Revenue Code (Code), which imposes an excise tax on remuneration in excess of $1,000,000 and any excess parachute payment paid by an applicable tax-exempt organization to any covered employee. The regulations affect certain tax-exempt organizations and certain entities that are treated as related to those organizations.
Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Related Information Reporting Requirements
Document Number: 2021-00741
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations providing guidance on section 162(f) of the Internal Revenue Code (Code), as amended in 2017, concerning the deduction of certain fines, penalties, and other amounts. This document also contains final regulations providing guidance relating to the information reporting requirements under new section 6050X of the Code with respect to those fines, penalties, and other amounts. The final regulations affect taxpayers that pay or incur amounts to, or at the direction of, governments, governmental entities or certain nongovernmental entities treated as governmental entities relating to the violation of any law or investigations or inquiries by such governments, governmental entities, or nongovernmental entities into the potential violation of any law. The final regulations also affect governments, governmental entities, and nongovernmental entities subject to the related reporting requirements.
Excise Taxes; Transportation of Persons by Air; Transportation of Property by Air; Aircraft Management Services
Document Number: 2021-00706
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to the excise taxes imposed on certain amounts paid for transportation of persons and property by air. Specifically, the final regulations relate to the exemption for amounts paid for certain aircraft management services. The final regulations also amend, revise, redesignate, and remove provisions of existing regulations that are out-of-date or obsolete and generally update the existing regulations to incorporate statutory changes, case law, and other published guidance. The final regulations affect persons that provide air transportation of persons and property, and persons that pay for those services.
Section 199A Rules for Cooperatives and Their Patrons
Document Number: 2021-00667
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance to cooperatives to which sections 1381 through 1388 of the Internal Revenue Code (Code) apply (Cooperatives) and their patrons regarding the deduction provided by section 199A(a) of the Code for qualified business income (QBI), as well as guidance to specified agricultural or horticultural cooperatives (Specified Cooperatives) and their patrons regarding the deduction provided by section 199A(g) of the Code for eligible domestic production activities undertaken by Specified Cooperatives. The final regulations also provide guidance on section 199A(b)(7), the statutory rule requiring patrons of Specified Cooperatives to reduce their QBI deduction under section 199A(a). In addition, the final regulations include a definition of patronage and nonpatronage sourced items under section 1388 of the Code, and revise existing regulations under section 1382 of the Code to reference this definition. Finally, this document removes the final and temporary regulations under former section 199. These final regulations affect Cooperatives as well as patrons that are individuals, partnerships, S corporations, trusts, and estates engaged in domestic trades or businesses.
Guidance Under Section 1061
Document Number: 2021-00427
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance under section 1061 of the Internal Revenue Code (Code). Section 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains. An applicable partnership interest is an interest in a partnership that is transferred to or held by a taxpayer, directly or indirectly, in connection with the performance of substantial services by the taxpayer, or any other related person, in any applicable trade or business. These final regulations also amend existing regulations on holding periods to clarify the holding period of a partner's interest in a partnership that includes in whole or in part an applicable partnership interest and/or a profits interest. These regulations affect taxpayers who directly or indirectly hold applicable partnership interests in partnerships and the passthrough entities through which the applicable partnership interest is held.
Additional Guidance Regarding Limitation on Deduction for Business Interest Expense
Document Number: 2021-00150
Type: Rule
Date: 2021-01-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide additional guidance regarding the limitation on the deduction for business interest expense under section 163(j) of the Internal Revenue Code (Code) to reflect amendments made by the Tax Cuts and Jobs Act and the Coronavirus Aid, Relief, and Economic Security Act. Specifically, the regulations address the application of the limitation in contexts involving passthrough entities, regulated investment companies (RICs), and controlled foreign corporations. The regulations also provide guidance regarding the definitions of real property development, real property redevelopment, and syndicate. The regulations affect taxpayers that have business interest expense, particularly passthrough entities, their partners and shareholders, as well as foreign corporations and their United States shareholders. The regulations also affect RICs that have business interest income, RIC shareholders that have business interest expense, and corporations that are members of a consolidated group.