This Week’s Internal Revenue Bulletin

HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

EXEMPT ORGANIZATIONS

Rev. Proc. 2021-8, page 502. This revenue procedure makes certain modifications to Rev. Proc. 2021-5 to allow for the new electronic submission process on www.pay.gov for the Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code. It also provides a 90-day transition relief period, during which paper Form 1024-A applications will be accepted by EO Determinations.

EMPLOYEE PLANS

T.D. 9937, page 495. This document sets forth final regulations relating to amendments made to section 402(c) of the Internal Revenue Code (Code) by section 13613 of the Tax Cuts and Jobs Act, Public Law 115-97 (131 Stat. 2054) (TCJA). Section 13613 of TCJA provides an extended rollover period for a qualified plan loan offset, which is a type of plan loan offset.

INCOME TAX

Rev. Proc. 2021-10, page 503. Rev. Proc. 2021-10 provides procedures for an issuer of tax-advantaged bonds to request an administrative appeal to the Independent Office of Appeals (Appeals) of a proposed adverse determination made by the office that is responsible for examinations of tax-advantaged bonds, presently the Office of Tax Exempt Bonds, with respect to issues within the scope of this revenue procedure.

Rev. Rul. 2021-2, page 495. This revenue ruling obsoletes Notice 2020-32, 2020-21 I.R.B. 837 and Revenue Ruling 2020-27, 2050-50 I.R.B. 1552, relating to the deductibility of certain expenses paid for with proceeds from a Paycheck Protection Program loan, due to the enactment of section 276(a) of the COVID-related Tax Relief Act of 2020.

TAX CONVENTIONS

Ann. 2021-1, page 506. The Competent Authorities of the United States and Italy entered into a Competent Authority Arrangement under paragraph 3 of Article 25 (Mutual Agreement Procedure) clarifying the application of subparagraph 1(b) of Article 19 (Government Services) with respect to remuneration paid by the United States to U.S. citizens or dual nationals who are residents of Italy and who are rendering services to the United States in U.S. embassies and consulates in Italy.