IRS releases tax reform guidance priorities

Tax Hot Topics newsletterThe 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

Contact Dustin Stamper
Director, Washington National Tax Office
T +1 202 861 4144

Shamik Trivedi
Senior Manager, Washington National Tax Office
T +1 202 521 1511

Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.

The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.