HIGHLIGHTS Bulletin No. 2020–18 OF THIS ISSUE
HIGHLIGHTSOF THIS ISSUE Bulletin No. 2020–18April 27, 2020These synopses are intended only as aids to the reader inidentifying the subject matter covered. They may not berelied upon as authoritative interpretations.ADMINISTRATIVENotice 2020-23, page 742.This notice amplifies Notice 2020-18 and Notice 2020-20,and provides additional tax relief under section 7508A ofthe Code for taxpayers affected by the Coronavirus Disease (COVID-19) emergency. Specified Federal tax filingsand payments due on or after April 1, 2020, and beforeJuly 15, 2020, are postponed to July 15, 2020. Specifiedtime-sensitive actions due to be performed on or after April1, 2020, and before July 15, 2020, are also postponedto July 15, 2020. This notice also postpones due dateswith respect to certain government acts and postpones theapplication date to participate in the Annual Filing SeasonProgram.Rev. Proc. 2020-23, page 749.On March 27, 2020, Congress passed the Coronavirus Aid,Relief, and Economic Security Act (CARES Act), providingbroad tax relief for taxable years beginning in 2018 and2019. By that time, many partnerships had already filedtheir returns for taxable years 2018 and 2019. The newcentralized partnership audit regime under the BipartisanBudget Act of 2015 (BBA) put in place restrictions undersection 6031(b) on amending partnership return information. Accordingly, BBA partnerships are generally prohibited from amending the information on Schedules K-1 andmust file an administrative adjustment request (AAR) undersection 6227. Partners generally would not receive benefits from AARs until 2021. This revenue procedure allowsBBA partnerships to file amended returns, issue amendedSchedules K-1, and for partners to receive benefits fromthe CARES Act this year.Rev. Proc. 2020-24, page 750.Rev. Proc. 2020-24 provides guidance under sections172(b)(1) and 172(b)(3), as amended by the CoronavirusAid, Relief, and Economic Security Act of 2020 (CARESAct)). Section 2303 of the CARES Act amended sectionFinding Lists begin on page ii.172 to require taxpayers with net operating losses (NOLs)arising in taxable years beginning in 2018, 2019, and2020 to carry those NOLs back for the 5 preceding taxableyears, unless the taxpayer elects to waive or reduce thecarryback period. The revenue procedure describes howtaxpayers with NOLs arising in taxable years 2018, 2019,or 2020 can elect to either waive the carryback period forthose losses entirely or to exclude from the carryback period for those losses any years in which the taxpayer has aninclusion in income as a result of section 965(a).ADMINISTRATIVE, INCOME TAXNotice 2020-26, page 744.This notice provides relief for certain taxpayers to allow themto take advantage of amendments made to the net operatingloss (NOL) provisions set forth in § 172 of the Internal Revenue Code (Code) by section 2303 of the Coronavirus Aid,Relief, and Economic Security Act (CARES Act), Public Law116-136, 134 Stat. 281 (March 27, 2020). Specifically, thisnotice extends the deadline for filing an application for a tentative carryback adjustment under § 6411 of the Code withrespect to the carryback of an NOL that arose in any taxableyear that began during calendar year 2018 and that endedon or before June 30, 2019.INCOME TAXT.D. 9896, page 681.Final regulations implementing sections 245A(e) and 267Aof the Internal Revenue Code regarding hybrid dividendsand certain amounts paid or accrued in hybrid transactionsor with hybrid entities. This document also contains finalregulations under: (1) sections 1503(d) and 7701 to prevent the same deduction from being claimed under the taxlaws of both the United States and a foreign country, and(2) sections 6038, 6038A, and 6038C to facilitate administration of these rules.
Rev. Proc. 2020-22, page 745.This revenue procedure provides guidance under section163(j) relating to elections to be an electing real propertyor farming trade or business. This revenue procedure alsoprovides the time and manner for making three electionsunder section 2306 of the CARES Act relating to the section 163(j) limitation.Rev. Proc. 2020-26, page 753.This revenue procedure provides guidance relating to thetax qualification of certain securitization vehicles that holdmortgage loans for which borrowers have participated inforbearance programs arising from the COVID-19 emergency. This revenue procedure also provides guidance for certain real estate mortgage investment conduits (REMICs) thatacquire mortgage loans for which borrowers have partici-pated in forbearance programs arising from the COVID-19emergency.REG-106013-19, page 757.Proposed regulations which provide rules for adjusting hybrid deduction accounts under I.R.C. §245A(e) to take intoaccount earnings and profits of a controlled foreign corporation that are included in income under U.S. tax law byreason of provisions other than section 245A(e). This document also contains proposed regulations that address, forpurposes of the conduit financing rules under I.R.C. §§881and 7701(l), multiple-party financing arrangements effected through the use of hybrid arrangements. In addition,this document contains proposed regulations under I.R.C.§951A relating to the treatment of certain payments madeduring a disqualified period.
The IRS MissionProvide America’s taxpayers top-quality service by helpingthem understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.IntroductionThe Internal Revenue Bulletin is the authoritative instrumentof the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Serviceand for publishing Treasury Decisions, Executive Orders, TaxConventions, legislation, court decisions, and other items ofgeneral interest. It is published weekly.It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform applicationof the tax laws, including all rulings that supersede, revoke,modify, or amend any of those previously published in theBulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements ofinternal practices and procedures that affect the rights andduties of taxpayers are published.Revenue rulings represent the conclusions of the Serviceon the application of the law to the pivotal facts stated inthe revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,identifying details and information of a confidential nature aredeleted to prevent unwarranted invasions of privacy and tocomply with statutory requirements.Rulings and procedures reported in the Bulletin do not have theforce and effect of Treasury Department Regulations, but theymay be used as precedents. Unpublished rulings will not berelied on, used, or cited as precedents by Service personnel inthe disposition of other cases. In applying published rulings andprocedures, the effect of subsequent legislation, regulations,court decisions, rulings, and procedures must be considered,and Service personnel and others concerned are cautionedagainst reaching the same conclusions in other cases unlessthe facts and circumstances are substantially the same.The Bulletin is divided into four parts as follows:Part I.—1986 Code.This part includes rulings and decisions based on provisionsof the Internal Revenue Code of 1986.Part II.—Treaties and Tax Legislation.This part is divided into two subparts as follows: Subpart A,Tax Conventions and Other Related Items, and Subpart B,Legislation and Related Committee Reports.Part III.—Administrative, Procedural, and Miscellaneous.To the extent practicable, pertinent cross references to thesesubjects are contained in the other Parts and Subparts. Alsoincluded in this part are Bank Secrecy Act AdministrativeRulings. Bank Secrecy Act Administrative Rulings are issuedby the Department of the Treasury’s Office of the AssistantSecretary (Enforcement).Part IV.—Items of General Interest.This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.The last Bulletin for each month includes a cumulative indexfor the matters published during the preceding months. Thesemonthly indexes are cumulated on a semiannual basis, and arepublished in the last Bulletin of each semiannual period.The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.April 27, 2020 Bulletin No. 2020–18
Part I26 CFR 1.245A(e)-1, 1.267A-1 through 1.267A-7,1.1503(d)-1, 1.1503(d)-3, 1.1503(d)-7, 1.1503(d)-8,1.6038-2, 1.6038-3, 1.6038A-2, 301.7701-3.T.D. 9896DEPARTMENT OF THETREASURYInternal Revenue Service26 CFR Parts 1 and 301Rules Regarding CertainHybrid ArrangementsAGENCY: Internal Revenue Service(IRS), Treasury.ACTION: Final regulations.SUMMARY: This document contains finalregulations providing guidance regardinghybrid dividends and certain amounts paidor accrued pursuant to hybrid arrangements, which generally involve arrangements whereby U.S. and foreign tax lawclassify a transaction or entity differentlyfor tax purposes. This document also contains final regulations relating to dual consolidated losses and entity classificationsto prevent the same deduction from beingclaimed under the tax laws of both the United States and a foreign jurisdiction. Finally,this document contains final regulations regarding information reporting to facilitatethe administration of certain rules in the final regulations. The final regulations affecttaxpayers that would otherwise claim a deduction related to such amounts and certainshareholders of foreign corporations thatpay or receive hybrid dividends.DATES: Effective date: These regulationsare effective on April 8, 2020.Applicability dates: For dates of applicability, see §§1.245A(e)-1(h), 1.267A-7,1.1503(d)-8(b), 1.6038-2(m), 1.6038-3(l),1.6038A-2(g), and 301.7701-3(c).FOR FURTHER INFORMATION CONTACT: Tracy Villecco at (202) 317-6933or Tianlin (Laura) Shi at (202) 317-6936(not toll-free numbers).Bulletin No. 2020–18SUPPLEMENTARY INFORMATION:BackgroundSections 245A(e) and 267A were added to the Internal Revenue Code (“Code”)by the Tax Cuts and Jobs Act, Pub. L.No. 115-97 (2017) (the “Act”), whichwas enacted on December 22, 2017. OnDecember 28, 2018, the Department ofthe Treasury (“Treasury Department”)and the IRS published proposed regulations (REG-104352-18) under sections245A(e), 267A, 1503(d), 6038, 6038A,6038C, and 7701 in the Federal Register (83 FR 67612) (the “proposed regulations”). Terms used but not defined in thispreamble have the meaning provided inthe final regulations.A public hearing on the proposed regulations was scheduled for March 20, 2019,but it was not held because no speaker outlines were submitted to the IRS by the duedate for submission, March 15, 2019. TheTreasury Department and the IRS receivedwritten comments with respect to the proposed regulations. Comments receivedoutside the scope of this rulemaking aregenerally not addressed but may be considered in connection with future regulations.All written comments received in responseto the proposed regulations are available atwww.regulations.gov or upon request.Summary of Comments andExplanation of RevisionsI. OverviewThe final regulations retain the basicapproach and structure of the proposedregulations, with certain revisions. ThisSummary of Comments and Explanationof Revisions section discusses the revisions as well as comments received in response to the solicitation of comments inthe proposed regulations.II. Comments and Revisions to Proposed§1.245A(e)-1 – Special Rules for HybridDividendsA. BackgroundSection 245A(e) and the proposed regulations neutralize the double non-taxa-681 tion effects of a hybrid dividend or tieredhybrid dividend through either denyingthe section 245A(a) dividends receiveddeduction with respect to the dividendor requiring an inclusion under section951(a)(1)(A) (“subpart F inclusion”) withrespect to the dividend, depending onwhether the shareholder receiving the dividend is a domestic corporation or a controlled foreign corporation (“CFC”). Theproposed regulations require that certainshareholders of a CFC maintain a hybriddeduction account with respect to eachshare of stock of the CFC that the shareholder owns, and provide that a dividendreceived by the shareholder from the CFCis a hybrid dividend or tiered hybrid dividend to the extent of the sum of those accounts.A hybrid deduction account with respect to a share of stock of a CFC reflectsthe amount of hybrid deductions of theCFC that have been allocated to the share.In general, a hybrid deduction is a deduction or other tax benefit allowed to a CFC(or a related person) under a relevant foreign tax law for an amount paid, accrued,or distributed with respect to an instrument of the CFC that is stock for U.S. taxpurposes.B. Hybrid deductions1. Current Use of Deduction or Other TaxBenefitOne comment requested that for a deduction or other tax benefit allowed undera relevant foreign tax law to be a hybriddeduction, it must be used currently under the relevant foreign tax law and, thus,currently reduce foreign tax liability. Thecomment noted that a current use mightnot occur if, for example, the CFC has other deductions or losses under the relevantforeign tax law, or all of a CFC’s incomeis exempt income (for example, if the CFCis a holding company and all of its incomebenefits from a 100 percent participationexemption). The comment asserted thatabsent a current use of a deduction, doublenon-taxation does not occur.The Treasury Department and the IRShave determined that it would not be appropriate for a deduction or other tax benefit to be a hybrid deduction only to theApril 27, 2020
extent it is used currently. Even though adeduction or other tax benefit may not beused currently, it could be used in anothertaxable period – for example, as a resultof a net operating loss carrying over to asubsequent taxable year – and thus couldproduce double non-taxation. In addition,it could be complex or burdensome to determine whether a deduction or other taxbenefit is used currently (because it could,for example, require a factual analysis ofhow particular deductions offset items ofgross income under the relevant foreigntax law) and then, to the extent not usedcurrently, track the deduction or othertax benefit so that it is added to a hybriddeduction account only once it is in factused. Accordingly, the final regulationsdo not adopt the comment, and the regulations clarify that a deduction or othertax benefit may be a hybrid deductionregardless of whether it is used currentlyunder the relevant foreign tax law. See§1.245A(e)-1(d)(2).2. Coordination with ForeignDisallowance Rulesi. Thin capitalization and other rulesA comment requested that a deductionor other tax benefit not be a hybrid deduction if under the relevant foreign taxlaw the deduction or other tax benefit isdisallowed under a thin capitalization ruleor a rule similar to section 163(j). Similarto the comment discussed in part II.B.1 ofthis Summary of Comments and Explanation of Revisions section, the comment asserted that such a disallowed deduction orother tax benefit does not produce doublenon-taxation.The final regulations do not adopt thecomment for reasons similar to those discussed in part II.B.1 of this Summary ofComments and Explanation of Revisionssection. For example, a thin capitalizationrule or a rule similar to section 163(j) maysuspend rather than disallow a deduction,and thus may not prevent eventual double non-taxation. Moreover, because athin capitalization rule or a rule similarto section 163(j) generally applies to allotherwise allowable deductions, it wouldbe unduly complex and burdensome todetermine the extent to which an amountdisallowed under such a rule relates to aApril 27, 2020particular otherwise allowable deduction.Accordingly, the final regulations do notadopt the comment, and the regulationsclarify that the determination of whethera deduction or other tax benefit is allowedis made without regard to a rule that disallows or suspends deductions if a certain ratio or percentage is exceeded. See§1.245A(e)-1(d)(2)(ii)(A).ii. Foreign hybrid mismatch rulesThe proposed regulations do not provide rules to take into account the application of foreign hybrid mismatch rules– that is, hybrid mismatch rules under therelevant foreign tax law. Accordingly, ifsuch hybrid mismatch rules deny a deduction to neutralize a deduction/no-inclusion(“D/NI”) outcome, then, because the deduction is not allowed under the relevantforeign tax law, the deduction cannot be ahybrid deduction under the proposed regulations.The Treasury Department and the IRShave concluded that, in certain cases,whether a deduction or other tax benefit isa hybrid deduction should be determinedwithout regard to foreign hybrid mismatchrules (and thus without regard to whether such rules disallow the deduction).The determination should be made in thismanner in cases in which there is a closetemporal connection between the amountgiving rise to the deduction or other taxbenefit and the payment of the amount asa dividend for U.S. tax purposes. In thesecases, in order to prevent a D/NI outcome,the participation exemption under section245A(a) should not apply to the dividend,as opposed to the participation exemptionapplying to the dividend to the extent thatthe foreign hybrid mismatch rules disallow a deduction for the amount in order toneutralize a D/NI outcome.This approach more closely aligns therules of section 245A(e) with the approachset forth in the OECD/G20 report, Neutralising the Effects of Hybrid MismatchArrangements, Action 2: 2015 Final Report (the “Hybrid Mismatch Report”).Such an approach avoids potential circularity or other issues in cases in which theapplication of foreign hybrid mismatchrules depends on whether an amount willbe included in income under U.S. tax law.See Hybrid Mismatch Report, para. 35682 and Ex. 2.3. In addition, this approach isconsistent with an approach suggested ina comment (which was received beforethe proposed regulations were issued butafter the proposed regulations had beensubstantially developed) with respect tosection 245A generally.Accordingly, the final regulations provide that the determination of whether arelevant foreign tax law allows a deduction or other tax benefit for an amount ismade without regard to the application offoreign hybrid mismatch rules, providedthat the amount gives rise to a dividendfor U.S. tax purposes or is reasonably expected for U.S. tax purposes to give riseto a dividend that will be paid within 12months after the taxable period in whichthe deduction or other tax benefit wouldotherwise be allowed. See §1.245A(e)1(d)(2)(ii)(B).As an example, assume that but for foreign hybrid mismatch rules, a CFC wouldbe allowed a deduction under the relevantforeign tax law for an amount paid or accrued pursuant to an instrument issued bythe CFC and treated as stock for U.S. taxpurposes. If the amount is an actual payment that gives rise to a dividend for U.S.tax purposes (or the amount is an accrualbut is reasonably expected to give rise toa dividend for U.S. tax purposes that willbe paid within 12 months after the taxableperiod for which the deduction wouldotherwise be allowed), then the amountgenerally gives rise to a hybrid deductionregardless of whether the foreign hybridmismatch rules may disallow a deductionfor the amount. If, on the other hand, theamount would give rise to a dividend ina later period, then the amount would notgive rise to a hybrid deduction to the extent that the foreign hybrid mismatch rulesdisallow a deduction for the amount.3. Effect of Withholding TaxesUnder the proposed regulations, thedetermination of whether a deduction orother tax benefi
This notice amplifies Notice 2020-18 and Notice 2020-20, and provides additional tax relief under section 7508A of the Code for taxpayers affected by the Coronavirus Dis-ease (COVID-19) emergency. Specified Federal tax filings and payments due on or after April 1, 2020, and before July 15, 2020, are postponed to July 15, 2020. Specified time-sensitive actions due to be performed on or after .
EU Tracker Questions (GB) Total Well Total Badly DK NET Start of Fieldwork End of Fieldwork 2020 15/12/2020 16/12/2020 40 51 9-11 08/12/2020 09/12/2020 41 47 12-6 02/12/2020 03/12/2020 27 57 15-30 26/11/2020 27/11/2020 28 59 13-31 17/11/2020 18/11/2020 28 60 12-32 11/11/2020 12/11/2020 28 59 12-31 4/11/2020 05/11/2020 30 56 13-26 28/10/2020 29/10/2020 29 60 11-31
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