Daily Tax Update - August 26, 2014: IRS Releases New Priority Guidance Plan

IRS Releases New Priority Guidance Plan:  The IRS released its 2014-2015 Priority Guidance Plan today.  The plan contains 317 projects that are priorities for allocation of IRS resources during the period from July 2014 through June 2015.  Among the new projects identified are guidance on qualifying income for publicly traded partnerships under Section 7704(d)(1)(E).  In March, the IRS announced that it had temporarily stopped considering private letter ruling requests on whether a publicly traded partnership satisfies the qualifying income requirements of Section 7704.  Other new priorities include regulations on a number of consolidated return issues and guidance related to captive insurance companies.

The Priority Guidance Plan can be accessed here

IRS and Treasury Issue Final Regulations Concerning Straddles:  The IRS and Treasury Department issued regulations under Section 1092 today, relating to debt that is a position in personal property that is part of a straddle.  A debt or obligation generally is not considered property of the debtor or obligor for Section 1092 purposes, and hence cannot be part of a straddle.  The regulations provide that if a taxpayer is the obligor under a debt instrument on which one or more payments are linked to the value of personal property or a position with respect to personal property, then the taxpayer’s obligation under the debt instrument is a position with respect to personal property and may be part of a straddle.  The regulations finalize temporary regulations issued in September 2013.

TIGTA Releases Audit of External Leads Program:  The Treasury Inspector General of Tax Administration (TIGTA) publicly released its audit of the IRS External Leads Program today.  Under the External Leads Program, the IRS receives leads about questionable tax refunds identified by a variety of partner organizations that include financial institutions, brokerage firms, government and law enforcement agencies, tax preparation entities, and others.  TIGTA found that the program had grown from 10 partner financial institutions returning $233 million in calendar year 2010 to 258 partner financial institutions and partner organizations returning more than $576 million in calendar year 2013.  TIGTA also recommended some changes to the verification process for leads.

The report can be accessed here.