Daily Tax Update - May 19, 2015: IRS and Treasury Issue Proposed Regulations for Banks That Receive Federal Financial Assistance

IRS and Treasury Issue Proposed Regulations for Banks That Receive Federal Financial Assistance:  The IRS and Treasury issued proposed regulations under section 597 of the Internal Revenue Code.  The proposed regulations would modify and clarify treatment of transactions in which banks and domestic building and loan associations receive federal financial assistance (FFA).  The proposed regulations remove references to “highest guaranteed value” and instead provide guidance on the determination of fair market value of covered assets.  The proposed regulations also provide guidance for certain transactions involving non-consolidated affiliates of an institution, and make changes to facilitate e-filing.  Comments on the proposed regulations are requested by August 18, 2015.

IRS Clarifies Effect of Patriots’ Day and Emancipation Day on Certain Deadlines:  In Revenue Ruling 2015-13 the IRS clarifies the due date for estimated tax payments and income tax returns when the due date falls on a Saturday, Sunday, or legal holiday such as Emancipation Day or Patriots’ Day.  Emancipation Day is typically observed in DC on April 16 and Patriots’ Day is observed in Massachusetts and Maine on the third Monday of April.  When Emancipation Day falls on Saturday, the legal holiday is observed on Friday, April 15 and the individual tax return filing deadline is extended to Monday, April 18.  In such instances, the statewide observation of Patriots’ Day on April 18 would further extend the filing deadline for residents of Maine and Massachusetts to Tuesday, April 19. However, estimated tax payments still would be due on Monday, April 18 for residents of Maine and Massachusetts.