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.

ADMINISTRATIVE

Rev. Rul. 2020-18, page 584. Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the calendar quarter beginning October 1, 2020, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for underpayments, and 5 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 0.5 percent.

INCOME TAX

Notice 2020-69, page 604. This notice announces that the Department of the Treasury and the Internal Revenue Service intend to issue regulations addressing the application of §§ 951 and 951A of the Internal Revenue Code to certain S corporations (as defined in § 1361(a)(1)) with accumulated earnings and profits, as described in § 316(a)(1). This notice also announces that the Treasury Department and the IRS intend to issue regulations addressing the treatment of qualified improvement property under the alternative depreciation system of § 168(g) for purposes of calculating qualified business asset investment for purposes of the foreign-derived intangible income and global intangible low-taxed income provisions, which were added to the Code by the enactment of Public Law No. 115-97, 131 Stat. 2054 (2017), commonly referred to as the Tax Cuts and Jobs Act (TCJA).

T.D. 9906, page 579. Nuclear Decommissioning Funds. Section 468A allows a taxpayer to elect to currently deduct amounts set aside in a qualified nuclear decommissioning fund for the purpose of decommissioning a nuclear power plant. These regulations provide rules concerning the use of those funds to decommission nuclear power plants. Specifically, the regulations revise and clarify certain provisions in existing regulations to address issues that have arisen as more nuclear plants have begun the decommissioning process. The regulations also clarify provisions in existing regulations regarding self-dealing and the definition of substantial completion of decommissioning.