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This Week's Internal Revenue Bulletin

AUG. 24, 2020

2020-35 IRB 1

DATED AUG. 24, 2020
DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-32388
  • Tax Analysts Electronic Citation
    2020 TNTF 163-21
    2020 TNTG 163-29
Citations: 2020-35 IRB 1

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.

ADMINISTRATIVE

REG-132434-17, page 508. These proposed regulations interpret new section 7602(f)'s restrictions on the non-governmental persons (contractors) to whom the IRS may provide books, papers, records, or other data for the sole purpose of providing expert evaluation and assistance to the IRS. Ancillary contractors, such as court reporters, translators or interpreters, photocopy services, providers of data processing programs or equipment, litigation support services, and other similar contractors may continue to assist the IRS in its examinations of taxpayers, but the IRS will not hire certain types of non-governmental attorneys for these purposes. No person other than an officer or employee of the IRS or IRS Chief Counsel may, on behalf of the IRS, question a witness under oath as part of an examination, but IRS contractors who are court reporters or foreign language interpreters may continue to play their customary roles in asking a witness certain non-substantive questions in a summons interview.

ADMINISTRATIVE, EXCISE TAX

Notice 2020-55, page 467. Notice 2020-55 provides expanded disaster relief, in the form of postponing until October 31, 2020, certain Federal excise tax filing and payment deadlines, and associated interest, penalties, and additions to tax, for taxpayers who owe a federal excise tax for sales of sport fishing or archery equipment for the first quarter of 2020.

EMPLOYEE PLANS

Notice 2020-61, page 468. The notice provides guidance regarding the special rules relating to single-employer defined benefit pension plans under § 3608 of the CARES Act. Under these special rules, a contribution that would otherwise be required to be made to such a plan during 2020 is required to be made by January 1, 2021, and special interest adjustment rules apply to a contribution that is made after the otherwise applicable deadline. In addition, an employer may elect to apply the benefit restrictions for underfunded plans under § 436 of the Code for the 2020 plan year (or a fiscal plan year that contains any part of 2020) using the plan's funded status for the last plan year ending in 2019.

Notice 2020-62, page 476. Notice 2020-62 modifies the two safe harbor explanations in Notice 2018-74, 2018-40 I.R.B. 529, that may be provided to recipients of eligible rollover distributions to satisfy the notice requirements under § 402(f). The safe harbor explanations, as modified by this notice, take into consideration certain legislative changes, including changes related to the Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”), and include other clarifying changes.

INCOME TAX

Announcement 2020-13, page 492. A copy of the Competent Authority Arrangement entered into by the competent authorities of the United States of America and Switzerland, arranging the implementation of the arbitration process provided for in paragraphs 6 and 7 of Article 25 of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income.

Notice 2020-63, page 491. This notice modifies Notice 2006-09, 2006-6 I.R.B. 413 and Notice 2008-33, 2008-12 I.R.B. 642, 2008, by providing a new address to which a vehicle manufacturer (or, in the case of a foreign vehicle manufacturer, its domestic distributor) must send vehicle certifications and quarterly reports.

DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-32388
  • Tax Analysts Electronic Citation
    2020 TNTF 163-21
    2020 TNTG 163-29
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