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New IRS FAQ's, Draft W-4s, and Hurricane Season: Weekly IRS Round-up, June 4 – 8

In order to continue to keep our readers informed on tax matters, we will be rolling out weekly posts on significant Internal Revenue Service (IRS) guidance and relevant tax cases. This post marks our first round-up of IRS guidance for the week June 4 – 8, 2018.

June 4, 2018: The IRS issued 3 new FAQs (supplementing the original 14 tax reform FAQs) which announce that it will waive certain late-payment penalties relating to the section 965 transition tax.

June 4, 2018: The IRS issued Internal Revenue Bulletin No. 2018-23 including: Rev. Proc. 2018-32 (combining guidance for grantors and contributors to tax-exempt organizations); Rev. Proc. 2018-34 (providing indexing adjustments for certain provisions under section 36B); Rev. Rul. 2018-14 (obsoleting Rev. Rul. 68-59, 1968-1 C.B. 273); Rev. Rul 2018-15 (obsoleting Rev. Rul. 74-487, 1974-2 C.B. 82; Rev. Rul. 75-211, 1975-1 C.B. 86; Rev. Rul. 77-115, 1977-1 C.B. 154; Rev. Rul. 77-407, 1977-2 C.B. 77; and, Rev. Rul. 80-11, 1980-1 C.B. 58); and Rev. Rul. 2018-16 (providing the prescribed federal interest rates for June 2018).

June 7, 2018: The IRS issued an early release draft of Form W-4, Employee’s Withholding Allowance Certificate seeking comments from industry.

June 7, 2018: With hurricane season underway, the IRS warns taxpayers that scammers often try to take advantage of the generosity of taxpayers who want to help victims of major disasters.

June 8, 2018: The IRS issued final regulations under sections 337 and 732 that: (1) prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner or certain related entities, (2) allow consolidated group members that are partners in the same partnership to aggregate their bases in stock for certain purposes and (3) that may require certain corporations that engage in gain elimination transactions to reduce the basis of corporate assets or to recognize gain.

June 8, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

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About this Author

Todd Welty P.C., McDermott Will Emery, Certified Public Accountant, Tax Controversy Attorney,
Partner

Todd Welty, P.C. is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Dallas office. Todd is Co-Chair of McDermott’s Tax Controversy Practice.

Todd’s practice is both national and international in scope. Approximately 95 percent of his professional time is spent on tax controversy and litigation. He represents a broad range of clients including Fortune 100 companies, large non-U.S. multinational companies, closely-held businesses, ultra-high-net-worth individuals and tax advisors – whether they be lawyers or...

214 295 8082
Laura L. Gavioli, P.C., McDermott Will Emery

Laura L. Gavioli, P.C. is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Dallas office. Laura is a member of McDermott’s U.S. and International Tax Practice Group. She specializes in handling complex civil tax audits, administrative appeals, and litigation. Laura is comfortable and seasoned in the court room, having litigated numerous civil tax cases in U.S. Tax Court and federal district court venues around the country.

Her experience includes significant taxpayer victories in civil tax cases in U.S. Tax Court and federal district court eliminating IRS penalties due to clients’ good faith and reasonable cause. She has also litigated numerous cases addressing complex jurisdictional questions under taxation statutes and setting precedent favorable to clients regarding statutes of limitations. Laura has also represented numerous clients in criminal tax investigations and prosecutions.

214-295-8079
Elizabeth Erickson, McDermott Will Emery Law Firm, Tax Attorney
Partner

Elizabeth Erickson is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office.  She is a member of the U.S. & International Tax Practice Group, and focuses her practice on tax controversies, including tax litigation.

202-756-8097
Andrew R. Roberson tax attorney McDermott Will. Andy handles tax cases in Federal court, United States Tax Court
Partner

Andrew R. Roberson is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  Andy specializes in tax controversy and litigation matters, and has been involved in over 30 matters at all levels of the Federal court system, including the United States Tax Court, several US Courts of Appeal and the Supreme Court. 

Andy also represents clients, including participants in the CAP program, before the Internal Revenue Service Examination Division and Appeals Office, and has been successful in settling...

312-984-2732
Kevin Spencer, McDermott Will & Emery LLP , Tax Litigation Attorney
Partner

Kevin Spencer is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office.  He focuses his practice on tax controversy and litigation issues. 

Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions.

In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and...

202-756-8203