Major tax reform was approved by Congress in the Tax Cuts and Jobs Act (TCJA) on December 22, 2017. The IRS is implementing this major tax legislation that will affect both individuals and businesses. We will provide information and guidance to taxpayers, businesses and the tax community as it becomes available. REG-111950-20, Guidance on Passive Foreign Investment Companies and the Treatment of Qualified Improvement Property under the Alternative Depreciation System for Purposes of Sections 250(b) and 951A(d) PDF NPRM-REG-101657-20, Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income PDF NPRM-REG-110059-20, Ownership Attribution Under Section 958 for Purposes of Sections 367(a) and 954(c)(6) NPRM-REG-124737-19, Coordination of Extraordinary Disposition and Disqualified Basis Rules PDF NPRM-REG-116475-19, Rollover Rules for Qualified Plan Loan Offset Amounts PDF REG-107213-18, Guidance under Section 1061; Notice of Proposed Rulemaking PDF REG-132766-18, Small Business Taxpayer Exceptions Under Sections 263A, 448, 460 and 471 PDF NPRM-REG-112042-19, Excise Taxes; Transportation of Persons by Air; Transportation of Property by Air; Aircraft Management Services NPRM-REG-107911-18, Proposed regulations under section 163(j) PDF NPRM-REG-127732-19, Guidance under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax NPRM-REG-125716-18, Consolidated Net Operating Losses NPRM-REG-119307-19, Qualified Transportation Fringe, Transportation and Commuting Expenses under Section 274 NPRM-REG-117589-18, Statutory limitations on like kind exchanges NPRM-REG-118997-19, Dependent Defined; Notice of Proposed Rulemaking and Partial Withdrawal of Notice of proposed rulemaking NPRM-REG-122345-18, Tax on Excess Tax-Exempt Organization Executive Compensation NPRM-REG-100320-20, Income Tax Withholding on Certain Periodic Retirement and Annuity Payments Under Section 3405(a) NPRM-REG-124810-19, Guidance Clarifying Premium Tax Credit Unaffected by Suspension of Personal Exemption Deduction NPRM-REG-124327-19, Rehabilitation Credit Allocated over a 5-Year Period NPRM-REG-104591-18, Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information With Respect To Certain Fines, Penalties, and Other Amounts NPRM-REG-118295-18, Effect of 67(g) on Trusts and Estates NPRM-REG-106864-18, Unrelated Business Taxable Income Separately Computed for Each Trade or Business NPRM-REG-106013-19, Guidance Involving Hybrid Arrangements and the Allocation of Deductions Attributable to Certain Disqualified Payments under Section 951A (Global Intangible Low-Taxed Income) NPRM-REG-132529-17, Computation and Reporting of Reserves for Life Insurance Companies NPRM-REG-100814-19, Meals and Entertainment Expenses Under Section 274 NPRM-REG-132741-17, Income Tax Withholding from Wages NPRM-REG-125710-18, Revised Applicability Dates for Regulations under Section 382(h) Related to Built-in Gain and Loss NPRM-REG-100956-19, Source of Income from Certain Sales of Personal Property NPRM-REG-122180-18, Certain Employee Remuneration in Excess of $1,000,000 under IRC Section 162(m) NPRM-REG-107431-19, Treatment of Payments to Charitable Entities in Return for Consideration NPRM-REG-112607-19, Guidance on Base Erosion and Anti-Abuse Tax NPRM-REG-105495-19, Foreign Tax Credit NPRM-REG-131071-18, Eligible Terminated S Corporations PDF NPRM-REG-117062–18, Electing Small Business Trusts With Nonresident Aliens as Potential Current Beneficiaries REG-128246-18, Contribution Limits Applicable to ABLE Accounts NPRM-REG-104223-18, Ownership attribution under section 958 NPRM-REG-106808-19, Additional First Year Depreciation Deduction REG-125710-18, Regulations under Section 382(h) Related to Built-in Gain and Loss REG-104870-18, Taxable Year of Income Inclusion under an Accrual Method of Accounting REG-104554-18, Advance Payments for Goods, Services, and Other Items REG-101378-19, Determination of the Maximum Value of a Vehicle for Use with the Fleet-average and Vehicle Cents-per-mile Valuation Rules REG-105474-18, Guidance on Passive Foreign Investment Companies PDF REG-106877-18, Guidance on the Determination of the Section 4968 Excise Tax Applicable to Certain Private Colleges and Universities REG-118425-18, Section 199A Rules for Cooperative and their Patrons REG-101828-19, Guidance under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income) REG-106282-18, Limitation on Deduction for Dividends Received from Certain Foreign REG-105476-18, Withholding of Tax and Information Reporting with Respect to Interests in Partnerships Engaged in the Conduct of a U.S. Trade or Business PDF REG-120186-18 NPRM, Investing in Qualified Opportunity Funds PDF REG-120186-18, Request for Information on Data Collection and Tracking for Qualified Opportunity Zones PDF REG-103083-18, Information Reporting for Certain Life Insurance Contract Transactions and Modifications to the Transfer for Valuable Consideration Rules REG-104464-18, Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income PDF REG-106706-18, Estate and Gift Taxes; Differences in the Basic Exclusion Amount REG-104352-18, Rules Regarding Certain Hybrid Arrangements PDF REG-134652-18, NPRM - Qualified Business Income Deduction PDF REG-113604-18, Gain or Loss of Foreign Persons from Sale or Exchange of Certain Partnership Interests PDF REG-104259-18, Base Erosion and Anti-Abuse Tax REG-104872-18, Removal of Regulations on Advance Payments for Goods and Long-Term Contracts PDF REG-105600-18, Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Jobs Act REG-106089-18, Limitation on Deduction for Business Interest Expense REG-107163-18, Regulations to Prescribe Return and Time for Filing for Payment of Section 4960, 4966, 4967, and 4968 Taxes and to Update the Abatement Rules for Section 4966 and 4967 Taxes (TCJA added sections 4960 , Tax on excess tax-exempt organization executive compensation and 4968, Excise tax based on investment income of private colleges and universities to the Tax Code REG-103163-18, Modification of Discounting Rules for Insurance Companies REG-115420-18 (rescheduled), Investing in Qualified Opportunity Funds; Hearing REG-115420-18, Investing in Qualified Opportunity Funds REG-114540-18, Amount Determined Under Section 956 for Corporate United States Shareholders REG-104390-18, Guidance Related to Section 951A (Global Intangible Low-Taxed Income) REG-112176-18, Contributions in Exchange for State or Local Tax Credits REG-107892-18, Qualified Business Income Deduction (Income tax deduction for passthroughs) REG-104397-18, Additional First Year Depreciation Deduction (Bonus Depreciation for Certain Property) PDF REG-104226-18, Guidance Regarding the Transition Tax Under Section 965 and Related Provisions REG-103474-18, Tax Return Preparer Due Diligence Penalty under Section 6695(g) (Expands the scope of the tax return preparer due diligence penalty so that it applies with respect to eligibility to file a return or claim for refund as head of household.) PDF Tax Reform Guidance Topics Regulations Treasury Decisions (TDs) Revenue Procedures Revenue Rulings Notices