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February 9, 2018
2018-0298

IRS updates Priority Guidance Plan to add projects implementing some TCJA international provisions

The IRS has issued the second quarter update to its 2017-18 Priority Guidance Plan, adding new guidance projects to implement the changes enacted by the Tax Cuts and Jobs Act (TCJA). This Alert highlights additions related to international provisions.

Background

The IRS issued the initial 2017-18 Priority Guidance Plan in October 2017. The plan gives an overview of the projects that the IRS intends to address in the plan year ending June 30, 2018. As in prior years, the IRS updates the plan periodically to reflect additional guidance that it intends to publish. For a detailed discussion of the international projects included in the 2017-18 initial plan, see Tax Alert 2017-1782.

On December 22, 2017, the President signed into law the TCJA, overhauling the Internal Revenue Code and enacting a number of new and revised international tax provisions. For a detailed discussion of the TCJA international provisions (including those highlighted below), see Tax Alert 2017-2166.

New international projects

The second quarter update to the 2017-18 Priority Guidance Plan includes 18 new projects related to the implementation of the TCJA. The introduction to the plan update describes these projects as "near term priorities." The plan update also adds several other new projects relating to guidance that the IRS has issued over the past several months. Several of the TCJA implementation projects relate to international provisions, including:

1. Computational, definitional and other guidance under new Section 163(j)

2. Guidance implementing new Section 965 and other international sections of the TCJA (this guidance was published as Notice 2018-07 (see Tax Alert 2017-2232))

3. Guidance under new Section 1446(f) for dispositions of certain partnership interests (this guidance was published as Notice 2018-08 (see Tax Alert 2018-0073))

Implications

Taxpayers that are interpreting new Section 163(j), new Section 965, new Section 1446(f) and other international sections of the TCJA should continue to monitor the release of new guidance, and should consult with tax advisors as new guidance is issued.

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Contact Information
For additional information concerning this Alert, please contact:
 
International Tax Services
• Joshua Ruland(202) 327-7238;
• Joe Ryan(312) 879-6112;
 

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