17 August 2016

IRS and Treasury's 2016-2017 Priority Guidance Plan addresses various accounting method issues, including industry guidance

Each year, the Treasury Department's Office of Tax Policy and the IRS use the Priority Guidance Plan to identify and prioritize tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. On August 15, 2016, the IRS and Treasury Department released the 2016-2017 Priority Guidance Plan (the Plan). The Plan lists 281 priority publication projects intended to address significant issues during the Plan Year (July 1, 2016 to June 30, 2017). There are four more projects than were on the prior business plan. As in prior years, the IRS and Treasury will periodically update the status of Plan projects and may add projects to respond to developments arising during the Plan Year. The following Plan projects address important issues relevant to the Quantitative Services Group:

Code
Section

Type of
Guidance


Abstract


Notes

41

Regulations

Regulations on the exception from the definition of "qualified research" for internal use software under Section 41(d)(4)(E).

Carryover project from prior year. Proposed regulations were published on January 20, 2015.

41

Unspecified

Guidance concerning payroll provisions for research credit.

New

41

Regulations

Regulations on whether gross receipts include receipts from transactions between group members.

Carryover project from prior year. Proposed regulations were published on December 13, 2013.

41

Regulations

Regulations on the allocation of the research credit to corporations and trades or businesses under common control for purposes of section 41(f)(1).

Carryover project from prior year. Final, temporary and proposed regulations were published on April 3, 2015.

167 and 168

Unspecified

Guidance for determining whether certain assets used by a wireline telecommunication service provider are primarily used for providing one-way or two-way communication services.

Carryover project from prior year.

167 and 1031

Unspecified

Guidance on whether property held simultaneously for sale and for lease (i.e., "dual-use property") is eligible for depreciation deductions and like-kind exchange treatment.

Carryover project from prior year.

168(k) and 179(f)

Unspecified

Procedures for making certain elections necessitated by

Protecting Americans From Tax Hikes Act of 2015.

New

170(e)(3)

Unspecified

Guidance under Section 170(e)(3) regarding charitable contributions of inventory.

Carryover project from prior year.

199

Final Regulations

Relating to the amendments by the Tax Extenders and Alternative Minimum Relief Act of 2008.

Carryover project from prior year. Proposed regulations were published on August 27, 2015.

199

Final Regulations

Regarding allocation of W-2 wages in a short tax year and in an acquisition or disposition.

Carryover project from prior year. Proposed and temporary regulations were published on August 27, 2015.

199

Regulations

Addressing computer software.

Carryover project from prior year.

263(a)

Revenue Procedure

Addressing the capitalization of natural gas transmission and distribution property.

Carryover project from prior year. This item relates to an IIR (Industry Issue Resolution) project.

263A

Final Regulations

Addressing the inclusion of negative amounts in additional Section 263A costs.

Carryover project from prior year. Proposed regulations were published on September 5, 2012.

267

Regulations

Regarding the application of Reg. Section 1.267(b)-1(b) to partners and partnerships.

Carryover project from prior year.

446

Unspecified

Guidance on the effect of new financial accounting standards on tax accounting.

Carryover project from prior year.

446

Regulations

Addressing notional principal contracts (NPC) relating to the inclusion in income or deduction of a contingent nonperiodic payment and guidance relating to the character of payments made pursuant to an NPC.

Carryover project from prior year. Proposed regulations were published on February 26, 2004 and temporary and proposed regulations were published May 8, 2015.

446

Unspecified

Guidance relating to accounting for hedging transactions.

New

451

Regulations

Addressing advance payments received for goods and services, including amounts received in exchange for the sale or issuance of gift cards, trading stamps, and loyalty points that can be redeemed for goods or services.

Carryover project from prior year.

453A

Regulations

Addressing contingent payment sales.

Carryover project from prior year.

453B

Regulations

Addressing nonrecognition of gain or loss on the disposition of certain installment obligations.

Carryover project from prior year. Proposed regulations were published on December 23, 2014.

460

Regulations

Regarding home construction contracts and accounting for long-term contracts.

Carryover project from prior year. Proposed regulations were published on August 4, 2008.

460

Regulations

Applying the look-back interest rules to certain pass-through entities with tax-exempt owners.

Carryover project from prior year.

468A

Unspecified

Guidance under Section 468A (nuclear decommissioning costs)

Carryover project from prior year.

471

Regulations

Regulations concerning trade discounts received by merchants.

New

472

Regulations

Addressing the inventory price index computation method under Reg. Section 1.472-8.

Carryover project from prior year.

472

Regulations

Addressing last-in, first-out inventories, including rules for combining pools as a result of a change in method of accounting, certain corporate acquisitions, and certain nonrecognition transactions.

Carryover project from prior year.

475

Regulations

Addressing mark-to-market accounting.

Carryover project from prior year. Proposed regulations were published on January 4, 1995, and January 28, 1999.

Implications

Practitioners should monitor the Priority Guidance Plan projects for possible effects on transactions, filing and reporting.

However, it is important to note that the Plan is not an exclusive list of projects the IRS and Treasury will work on during the coming year. Listing on the Plan does not guarantee that the Government will publish a particular project by June 2017; projects may carry over to subsequent years or may be removed from the Plan without publication. Also, during the Plan Year, the IRS and Treasury may need to publish guidance on issues not identified on the original Plan. Practitioners should stay alert for such non-Plan developments.

———————————————

Contact Information
For additional information concerning this Alert, please contact:
 
International Tax Services
National Tax Quantitative Services
Brandon Carlton(202) 327-6826
Jack Donovan(202) 327-8054
Susan Grais(202) 327-8782
Alison Jones(202) 327-6684
Scott Mackay(202) 327-6069

Document ID: 2016-1412