Daily Tax Update - December 7, 2016: Joint Committee on Taxation Issues Summary of 2016 Tax Corrections Act

Joint Committee on Taxation Issues Summary of 2016 Tax Corrections Act:  The Joint Committee on Taxation released yesterday JCX-91-16, its summary of Tax Technical Corrections Act of 2016 making corrections to the Consolidated Appropriations Act of 2016 (P.L. 114-113).  Among the provisions affected by the Corrections Act are several regarding real estate investment trusts as well as clarifications involving transit parity, the research credit, bonus depreciation, the revocation of passports of seriously tax-delinquent individuals, and the American opportunity tax credit.  The bill would also make corrections and clarifications regarding partnership auditing rules enacted in the Bipartisan Budget Act of 2015 and amended by the 2015 Protecting Americans from Tax Hikes (PATH) Act.

IRS Publishes Guidance on Section 987 Qualified Business Units:  Today, the IRS issued three sets of guidance on the tax treatment of foreign currency gains or losses by subdivisions of taxpayers within a larger multinational company, known as “qualified business units,” under Section 987.  The guidance includes proposed rules REG-128276-12, temporary rules T.D. 9795, and final regulations T.D. 9794.  These rules address situations where taxpayers terminate a qualified business unit and situations involving partnerships.