Daily Tax Update - July 25, 2016: Section 83(b) Filing Requirement Removed in Final Rules

Section 83(b) Filing Requirement Removed in Final Rules:  Today, the IRS released final regulations relating to property transferred in connection with the performance of services.  The final regulations, which make no modifications to the proposed regulations released in July 2015, affect certain taxpayers who receive property transferred in connection with the performance of services and make an election to include the value of substantially nonvested property in income in the year of transfer.  The final regulations remove the second section in Treas. Reg. § 1.83-2(c) of the existing regulations, which requires that a taxpayer submit a copy of a section 83(b) election with the taxpayer’s tax return for the year in which the property subject to the election was transferred. 

International Organizations Release Report Making Recommendations for Implementing Technical Assistance Programs:  The Platform for Collaboration on Tax (the PCT) - comprised of the IMF, OECD, UN, and World Bank Group - responded to the February 2016 request from the G20 Finance Ministers to “recommend mechanisms to help ensure effective implementation of technical assistance programs, and recommend how countries can contribute funding for tax projects and direct technical assistance….”  The PCT released a report, which points to several “key enablers” to building tax capacity, including: (i) a coherent revenue strategy as part of a development financing plan; (ii) strong coordination among well-informed and results-oriented providers; (iii) a strong knowledge and evidence base; (iv) strong regional cooperation and support; and (v) strengthened participation of developing countries in international rule setting.  The report also arrives at a number of recommendations for measures to strengthen or achieve those enablers. 

Going forward, the PCT recommends a follow-up report within three years and stresses the importance of (i) support for developing countries to effectively participate in international tax policy discussions and institutions and (ii) work by international organizations to measure and report upon the impact of various interventions.   


Details in Ryan's Blueprint Indicate Shift in GOP Approach:  While tax reform has been discussed at length in recent years, and many have grown skeptical of the possibility for action in the near-term, the recently released House Tax Reform Task Force blueprint demonstrates continued interest in tax reform in the US Congress and lays additional groundwork for future action on reform.  In a recent op-ed for The Hill, Lisa Zarlenga and Cameron Arterton discuss the blueprint in greater detail.  To read more, click here.