Small Business Taxes & Management

IRS Pronouncements--2019

Note. The list below contains a synopses of revenue rulings, revenue procedures, notices, announcements and regulations beginning with those issued January 1, 2019. Because the IRS is no longer indexing the contents of the bulletins as in the past, we have created two indicies--this one is a complete list of all pronouncements. For an abbreviated list that is limited to those items we believe to be of interest to small to mid-sized business owners, their advisors, CPAs, enrolled agents, etc, go to IRS Pronouncements--2019--Short List. For a abbreviated, similar listing for prior years, go to:

IRS Pronouncements--2018
IRS Pronouncements--2017
IRS Pronouncements--2016
IRS Pronouncements--2015
IRS Pronouncements--2014
IRS Pronouncements--2013
IRS Pronouncements--2012
IRS Pronouncements--2011
IRS Pronouncements--2010
IRS Pronouncements--2009
IRS Pronouncements--2008
IRS Pronouncements--2007
IRS Pronouncements--2006
IRS Pronouncements--2005
IRS Pronouncements--2004
IRS Pronouncements--2003
IRS Pronouncements--2002
IRS Pronouncements--2001
IRS Pronouncements--2000

We've included the IRB (Internal Revenue Bulletin) reference so you can find the full text on the IRS web site. We've tried to make the list as searchable as possible while keeping the descriptions short. Use the "find-in-page" or "find" feature of your browser (CTRL-F) to search this list. Be sure to try variations of keywords such as "activities" as well as "activity"; "depreciation" as well as "depreciate". The Applicable Federal Rate and interest rates on over- and underpayments are updated on our IRS Interest Rates page.

Notes.

The list below includes pronouncements for the first 21 bulletins of 2019.
Entries for each section are in the order they appear in the bulletins.
Go to our Abbreviations page for details on any abbreviations.
Quick link to Individual Bulletins for 2019
If you know the number, you can access a PDF file of any recent Revenue Ruling, Revenue Procedure, or Notice at the IRS Web site directly. Simply paste the appropriate link below into your browser and enter the desired ruling, procedure, or notice number instead of the xx.

For Revenue Rulings-- www.irs.gov/pub/irs-drop/rr-19-xx.pdf
For Revenue Procedures-- www.irs.gov/pub/irs-drop/rp-19-xx.pdf
For Notices-- www.irs.gov/pub/irs-drop/n-19-xx.pdf

The xx must be at least two digits. Thus, Revenue Ruling 5 for 2019 would be: www.irs.gov/pub/irs-drop/rr-19-05.pdf For prior years, change the 19 to the appropriate year (available years vary).

New Additions - Bulletin 21

Rev. Proc. 2019-21 (IRB 2019-21) Sec. 143; 25; qualified mortgage bonds; mortgage credit certificates; median gross income figure.

Notice 2019-32 (IRB 2019-21) Sec. 45Q; request for comments; changes by Bipartisan Budget Act of 2018; BBA; carbon oxide; secure geological storage and measurement; recapture of credit.

Announcement 2018-4 (IRB 2019-21) Revocation of Sec. 501(c)(3) organizations for failure to meet requirements; contributions made to the organizations by individual donors no longer deductible.

For the full text of these rulings, go to Internal Revenue Bulletin 2019-21

Cumulative Listings - 2019

Revenue Rulings

Rev. Rul. 2019-13 (IRB 2019-20) Sec. 301; 302; 1368; 1377; cash distributions; C corporations that were formally S corporation; distribution should reduce corporations accumulated adjustment account.
Rev. Rul. 2019-12 (IRB 2019-19) Applicable federal rates; adjusted federal long-term rate; May, 2019.
Rev. Rul. 2019-11 (IRB 2019-17) Sec. 164; inclusion in income of recovered state and local taxes in current year when deducted taxes paid in a prior year; Sec. 164(b)(6) limitation.
Rev. Rul. 2019-10 (IRB 2019-16) Sec. 1.61-21(g); fringe benefits aircraft valuation formula; SIFL cents-per-mile rate; employer-provided aircraft; first half of 2019.
Rev. Rul. 2019-9 (IRB 2019-14) Sec. 355; rev. rul. suspends Rev. Rul. 57-464; Rev. Rul. 57-492; pending study on active trade or business requirement.
Rev. Rul. 2019-8 (IRB 2019-14) Applicable federal rates; adjusted federal long-term rate; April, 2019.
Rev. Rul. 2019-6 (IRB 2019-14) Sec. 401; tables of covered compensation effective January 1, 2019.
Rev. Rul. 2019-5 (IRB 2019-11) Interest rates on underpayments and overpayments; quarter beginning April 1, 2019.
Rev. Rul. 2019-7 (IRB 2019-10) Applicable federal rates; adjusted federal long-term rate; March, 2019.
Rev. Rul. 2019-4 (IRB 2019-7) Applicable federal rates; adjusted federal long-term rate; February, 2019.
Rev. Rul. 2019-3 (IRB 2019-2) Applicable federal rates; adjusted federal long-term rate; January, 2019.

Revenue Procedures

Rev. Proc. 2019-21 (IRB 2019-21) Sec. 143; 25; qualified mortgage bonds; mortgage credit certificates; median gross income figure.
Rev. Proc. 2019-20 (IRB 2019-20) Sec. 401; Rev. Proc. 2016-37; limited expansion of determination letter program for individually designed plans; remedial amendment period>
Rev. Proc. 2019-19 (IRB 2019-19) EPCRS correction program; expansion of SCP eligibility to permit corrections of certain Plan Document Failures; plan loan failures; additional method of correcting plan loan failures; Rev. Proc. 2018-52 modified and superseded.
Rev. Proc. 2019-18 (IRB 2019-18) Professional sports teams; safe harbor treatment for certain personnel contracts and rights to draft players; zero value for purposes of determining gain or loss on trade of personnel contracts or draft picks.
Rev. Proc. 2019-17 (IRB 2019-17) Sec. 142; 42(g)(9); general public use requirements for qualified residential rental projects financed with tax-exempt bonds; specified occupancy restrictions.
Rev. Proc. 2019-14 (IRB 2019-15) Sec. 143; 25; qualified mortgage bonds; QMBs; qualified mortgage certificates; MCC; purchase price safe harbors.
Rev. Proc. 2019-15 (IRB 2019-14) Sec. 911; waiver of time requirements for individuals electing to exclude foreign earned income; residence test; war, civil unrest, adverse conditions; countries added.
Rev. Proc. 2019-13 (IRB 2019-9) Depreciation deduction automobiles; Sec. 280F luxury car limits; 100-percent additional first-year depreciation; safe harbor method.
Rev. Proc. 2019-11 (IRB 2019-9) Sec. 199A; methods for calculating W-2 wages; limitation on qualified business income deduction; QBI.
Rev. Proc. 2019-12 (IRB 2019-4) Sec. 162; safe harbor for certain payments made by a C corporation or specified passthrough entity to an organization described in Sec. 170; entity expects to receive a state or local tax credit in return for certain payments.
Rev. Proc. 2019-8 (IRB 2019-3) Sec. 179; expensing qualified real property; change computation of depreciation to alternative depreciation system for years beginning after 2017; definition of qualified real property; Rev. Proc. 87-57 and 2018-31 modified.
Rev. Proc. 2019-10 (IRB 2019-2) Insurance companies; automatic consent to change accounting; Sec. 807; TCJA; Rev. Proc. 2018-31, Rev. Rul. 1994-74 and Rev. Rul. 2002-6 modified.
Rev. Proc. 2019-9 (IRB 2019-2) Annual adequate disclosure revenue procedure; disclosure of item on tax return with respect to an item or position; accuracy related penalty; Sec. 6662; return preparer penalty Sec. 6694; Rev. Proc. 2018-11 updated.
Rev. Proc. 2019-6 (IRB 2019-2) Insurance companies; uinpaid loss discount factors for 2018 accident year; Sec. 846, 832.
Rev. Proc. 2019-7 (IRB 2019-1) Areas of IRC under jurisdiction of Associate Chief Counsel (International); IRS will not issue determination letters or letter rulings.
Rev. Proc. 2019-5 (IRB 2019-1) Procedures for issuing determination letters; issues under jurisdiction of Director, Exempt Organizations; EO; rulings and agreements; pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans; private foundation status; Sec. 7428.
Rev. Proc. 2019-4 (IRB 2019-1) Revised procedures; determination letters and letter rulings issued by the Commissioner; Tax Exempt and Government Entities; Employee Plans Rulings and Agreements; Rev. Procs. 2018-4 superseded.
Rev. Proc. 2019-3 (IRB 2019-1) Revised list of areas where IRS will not issue letter rulings or determination letters; Corporate; Financial Institutions and Products; Income Tax and Accounting; Passthroughs and Special Industries; Procedure and Administration; Tax Exempt and Government Entities; Associate Chief Counsel; Rev. Proc. 2018-3 superseded.
Rev. Proc. 2019-2 (IRB 2019-1) Procedures for Technical advice memoranda; TAMS; taxpayer rights when field office requests TAMS; Rev. Proc. 2018-2 superseded.
Rev. Proc. 2019-1 (IRB 2019-1) Procedures for letter rulings and information letters; Associate Chief Counsel; Corporate; Financial Institutions and Products; Income Tax and Accounting; International; Passthroughs and Special Industries; Procedure and Administration; Tax Exempt and Government Entities; Rev. Proc. 2018-1 superseded.

Regulations

T.D. 9854 (IRB 2019-18) Sec. 148 arbitrage bond definition; definition of investment property; real or tangible personal property purchased in furtherance of the public purposes for which bonds issued.
T.D. 9855 (IRB 2019-17) Sec. 4960; 4966; 4967; 4968; 4963; Form 4720 to report excise tax; 15th day of fifth month; abate rules.
T.D. 9853 (IRB 2019-16) Sec. 6707A; calculation of penalty; Small Business Jobs Act of 2010; reportable transactions; penalty limits; penalty where no tax on return.
T.D. 9852 (IRB 2019-16) Sec. 1471; FATCA; withholding agents; finalization of proposed regulations; compliance requirements and verification procedures; FFIs and NFFEs.
T.D. 9851 (IRB 2019-14) Sec. 951; requirements to determine qualification for treatment as a regulated investment company; RIC; definition of dividends.
T.D. 9850 (IRB 2019-12) Sec. 42; utility allowance regulations concerning low-income housing credit; extension of current submetering rules; building owner independently generates and sells energy to tenants.
T.D. 9848 (IRB 2019-11) Sec. 42; compliance monitoring duties of state or local housing credit agency; revise and clarify certain rules; requirement to conduct physical inspections.
T.D. 9844 (IRB 2019-11) Centralized partnership audit regime; Bipartisan Budget Act of 2015; scope; requirement for consistent reporting; imputed underpayments, notices, assessments and penalties.
T.D. 9847 (IRB 2019-9) Sec. 199A; 20 percent deduction for qualified business income; QBI; pass-through entities and sole proprietorships; limitations of deductions; 20 percent deduction for qualified REIT dividends and publicly traded partnership income.
T.D. 9846 (IRB 2019-9) Sec. 965; U.S. persons with direct or indirect ownership interests in certain foreign corporations.
T.D. 9845 (IRB 2019-8) Sec. 147; private activity bond; not tax exempt unless approved by both the governmental unit issuing the bond and the governmental unit in which financed property is located; update to existing regulations; additional flexibility in satisfying approval requirement.

Proposed Regulations

REG-120186-18 (IRB 2018-21) Sec. 1400Z-2; QOF; qualified opportunity fund; gains that may be deferred; rules for 10-year holding period; definition of substantially all; transactions that may trigger gain; reasonable period for reinvestment of proceeds from sale of qualifying assets.
REG-117062-18 (IRB 2018-19) Statutory expansion of class of permissible potential current beneficiaries; electing small business trust; ESBT; income of S corporation subject to U.S. income tax when NRA is deemed owner of grantor trust.
REG-103083-18 (IRB 2018-17) Sec. 6050Y; new information reporting obligations related to reportable policy sales of life insurance contracts and payments of reportable death benefits; Tax Cuts and Jobs Act; death benefits excluded from gross income under Sec. 101.
REG-124627-11 (IRB 2018-17) Proposed rules withdrawn; REG-1246277-11.
REG-143686-07 (IRB 2018-17) Proposed rules withdrawn; recovery of stock basis in a distributions of property made by a corporation; dividend-equivalents; determination of gain and basis of stock or securities in certain transactions.
REG-113943-17 (IRB 2018-17) Rules, in part, withdrawn; property of C corporation transferred to REIT following certain corporate distributions of controlled stock.
REG-121694-16 (IRB 2018-16) Sec. 301; reflect changes by Technical and Miscellaneous Revenue Act of 1988; distribution of property by a corporation to its shareholder at fair market value of distributed property.
REG-135671-17 (IRB 2018-16) Sec. 337; corporate partner using a partnership to avoid recognition of corporate-level gain; defintion of Stock of the Corporate Partner.
REG-141739-08 (IRB 2018-9) Sec. 103; when tax-exempt bonds are treated as retired; satisfaction of verious eligibility requirements; rules for qualified tender bonds.
REG-134562-18 (IRB 2018-9) Sec. 199A; income from pass-through entities; qualified business income; QBI; previously suspended losses that constitute QBI.
REG-106089-18 (IRB 2018-5) Sec. 163; business interest deduction limitation; calculation of limitation; applicability of limitation; exceptions to limitation.
REG-104352-18 (IRB 2018-3) Sec. 245A; 267A; hybrid dividends; amounts paid or accrued in hybrid transactions; Sec. 1503; 7701; 6038; 6038A; 6038C; prevention of double deduction on U.S. and foreign tax return.
REG-104259-18 (IRB 2019-2) Additional tax on certain corporations; substantial gross receipts; certain paymens to foreign persons related to the corporations.

Notices

Notice 2019-32 (IRB 2019-21) Sec. 45Q; request for comments; changes by Bipartisan Budget Act of 2018; BBA; carbon oxide; secure geological storage and measurement; recapture of credit.
Notice 2019-31 (IRB 2019-20) Sec. 45Q; inflation adjustment factor for carbon dioxide sequestration credit; 2019; qualified carbon oxide in annual report.
Notice 2019-30 (IRB 2019-20) Solicitation of public comments recommending projects to be included in 2019-2020 Priority Guidance Plan.
Notice 2019-29 (IRB 2019-19) Corporate bond monthly yield curve April 2019; Sec. 417; 430; interest rate on 30-year Treasury securities.
Notice 2019-28 (IRB 2019-18) Sec. 45K; 43; 45L; 613A; reference price for enhanced oil recovery credit; marginal well production credkit; percentage depletion for oil produced from marginal properties.
Notice 2019-26 (IRB 2019-15) Sec. 430; 417; updated mortality tables; determining minimum funding standards; minimum present value.
Notice 2019-25 (IRB 2019-15) Waiver of addition to tax for underpayment of estimated tax for 2019 year; 80-percent waiver; Notice 2019-11 updated and superseded.
Notice 2019-23 (IRB 2019-15) Update to appendix to Notice 2013-1; tribes that have resolved claims agains the U.S.
Notice 2019-24 (IRB 2019-14) Sec. 911; adjustment to limitation on foreign housing expenses; table; application of adjustments to 2018 taxable year.
Notice 2019-22 (IRB 2019-14) Sec. 30D; qualified plug-in electric drive motor vehicle credit; phase out of credit for General Motors vehicles to begin April 1, 2019.
Notice 2019-21 (IRB 2019-14) Corporate bond monthly yield curve March 2019; Sec. 417; 430; interest rate on 30-year Treasury securities.
Notice 2019-20 (IRB 2019-14) Sec. 6722; 6698; 6038; penalty relief; failure to furnish correct payee statements; failure to file partnership return; failure to furnish K-1 or information about partner's negative basis.
Notice 2019-18 (IRB 2019-13) Sec. 401(a)(9); IRS no longer intends to amend required minimum distribution regulations; retirees and beneficiaries current receiving annuity payments under defined benefit plan; lump-sum payment in lieu of future annuity payments.
Notice 2019-10 (IRB 2019-13) Excise tax imposed on fuels in power takeoff or power transfer (PTO) to operate auxiliary equipment on motor vehicle; request for comments.
Notice 2019-19 (IRB 2019-12) Sec. 42; 142; 146; Population numbers for 2019 for determining state housing credit ceiling; private activity bond volume cap; private activity bond volume limit.
Notice 2019-17 (IRB 2019-12) Sec. 6654; waiver of penalty for understatement of estimated income tax by qualifying farmers and fisherman; return filed by April 15, 2019 with proper waiver form.
Notice 2019-16 (IRB 2019-10) Corporate bond monthly yield curve February 2019; Sec. 417; 430; interest rate on 30-year Treasury securities.
Notice 2019-7 (IRB 2019-9) Sec. 199A; safe harbor; rental real estate enterprise treated as a trade or business solely for purposes of Sec. 199A; satisfaction of requirements of proposed revenue procedure.
Notice 2019-13 (IRB 2019-8) Corporate bond monthly yield curve January 2019; Sec. 417; 430; interest rate on 30-year Treasury securities.
Notice 2019-11 (IRB 2019-4) Underpayment of estimted tax; waiver of penalties; 85 percent of 2018 liability.
Notice 2019-9 (IRB 2019-4) Sec. 4960; excise tax; excess remuneration and excess parachute payments paid by a tax-exempt organization; definitions.
Notice 2019-8 (IRB 2019-3) Sec. 61; fringe benefits; fleet-average and cents-per-mile special valuation rules; value personal use of employer provided vehicle.
Notice 2019-6 (IRB 2019-3) Sec. 6241; intent to propose regulations addressing certain enforcement matters; centralized partnership audit regime.
Notice 2019-3 (IRB 2019-3) Corporate bond monthly yield curve December 2018; Sec. 417; 430; interest rate on 30-year Treasury securities.
Notice 2019-5 (IRB 2019-2) Hardship exemption certification; minimum essential coverage; qualifying individual; Insurance Marketplace; Notice 2014-76 and 2017-14 expanded.
Notice 2019-4 (IRB 2019-2) Dyed fuel relief extended for that removed from Milwaukee and Madison terminals.
Notice 2019-2 (IRB 2019-2) Standard mileage rates; 2019; automobiles; maximum cost for FAVR plan; reductions to basis for depreciation taken.
Notice 2019-1 (IRB 2019-2) TCJA; foreign corporations with previously taxed earnings and profits; PTEP; maintenance of PTEP in annual accounts; ordering of PTEP upon distribution and reclassification.

Announcements

None Announcement 2018-4 (IRB 2019-21) Revocation of Sec. 501(c)(3) organizations for failure to meet requirements; contributions made to the organizations by individual donors no longer deductible.
Announcement 2018-3 (IRB 2019-15) Required annual report by Secretary of Treasury on advance pricing agreements; APA; Advance Princing and Mutual Agreement Program; APMA.
Announcement 2018-2 (IRB 2019-12) Office of Professional Responsibility; OPR; recent disciplinary sanctions.
Announcement 2019-1 (IRB 2019-6) Notification to Internal Revenue Bulletin users that there were no articles submitted for IRB 2019-6.

Action On Decision

Action on Decision 2019-1 (IRB 2019-8) Acquiescence in result only; professional hockey team's expenses for providing pregame meals at away city hotels fully deductible because provided on employer-operated facilities.

Links to Individual Bulletins

Copyright 2019 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information is not necessarily a complete summary of all materials on the subject. Copyright is not claimed on material from U.S. Government sources--ISSN 1089-1536

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--Last Update 05/18/19