The IRS has released an updated priority guidance plan that details the IRS’s top guidance priorities for implementing the tax reform bill. The plan includes an initial list of 18 areas (two of them have already been addressed), and the most expansive projects appear to be “computational, definitional and anti-avoidance” guidance on the new deduction for pass-through income under Section 199A and “computational, definitional, and other guidance” on the new interest limitation under Section 163(j).
The plan also pledges to provide guidance on the controversial grandfathering rules for the expansion of the limit on the deduction for executive compensation under Section 162(m). The other priority areas for guidance include:
- Expansion of bonus depreciation under Section 168(k)
- New requirements under Section 451 for recognizing income in the same year it is recognized for financial accounting
- Computations for the estate and gift taxes to reflect the new exclusion amount
- Expansion of the disallowance of deduction for fines and penalties under Section 162(f)
- New credit for wages paid to employees on family and medical leave under Section 45S
- New reporting requirements for life insurance contracts under Section 6050Y
- Changes to Section 529 plans
- Computations reflecting the changes to unrelated business income rules under Section 512
- Changes to allowable beneficiaries and charitable contribution rules for electing small business trusts under Section 1361
- New “Opportunity Zone” tax incentives under Section 1400Z
- Withholding under Section 3402 and 3405
- A new excise tax on compensation paid by tax exempt organizations under Section 4860
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