12 February 2018

IRS and Treasury update 2017-18 Priority Guidance Plan, addressing various accounting method issues

The IRS and Treasury have updated the 2017-18 Priority Guidance Plan (Plan or PGP), addressing various accounting method issues. The updated Plan includes an additional 29 guidance projects, some of which are the result of the enactment of the Tax Cuts and Jobs Act (the Act). For more information on the previous version of the 2017-18 Priority Guidance Plan, see Tax Alert 2017-1779. The PGP contains guidance projects that the Treasury and IRS are seeking to complete by June 30, 2018.

The following Plan projects address important accounting method and certain similar issues:

Code Section

Type of Guidance

Abstract

Notes

162(f) and new 6050X

Unspecified

Guidance under Section 162(f) and new Section 6050X.

New

New 163(j)

Unspecified

Computational, definitional and other guidance.

New

165

Revenue Procedure

Providing a safe harbor for amounts paid to repair damage to deteriorating concrete foundations caused by the presence of the mineral pyrrhotite.

Revenue Procedure 2017-60 released on November 22, 2017, and published in IRB 2017-50 on December 11, 2017.

165

Revenue Procedure

Providing loss safe harbor guidance.

Revenue Procedure 2018-08 released on December 13, 2017, and published in IRB 2018-02 on January 8, 2018.

165

Revenue Procedure

Providing Hurricane Harvey and Irma cost-index guidance.

Revenue Procedure 2018-09 released on December 13, 2017, and published in IRB 2018-02 on January 8, 2018.

166

Unspecified

Guidance on the conclusive presumption of worthlessness for bad debts.

Carryover project from prior year. Notice 2013-25, which requested comments on the existing rules, was published on June 10, 2013.

167

Revenue Procedure

Guidance on the safe harbor for normalization.

Revenue Procedure 2017-47 released on September 7, 2017, and published in IRB 2017-38 on September 18, 2017.

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.

New 168(k)

Unspecified

Guidance on new Section 168(k).

New

170

Final regulations

Regarding charitable contributions.

Carryover project from prior year. Proposed regulations were published on August 7, 2008.

170(e)(3)

Unspecified

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

Carryover project from prior year.

199

Unspecified

Guidance on qualified films.

Revenue Ruling 2018-3 released on December 21, 2017, and published in IRB 2018-2 on January 8, 2018.

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.

New 199A

Unspecified

Computational, definitional and anti-avoidance guidance.

New

263(a)

Revenue Procedure

Addressing the capitalization of natural gas transmission and distribution property.

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

263A, 448, 460 and 471

Unspecified

Guidance adopting new small business accounting method changes.

New

280F

Unspecified

Guidance clarifying whether the business use of an aircraft by a lessee that is a 5% owner or related party of the lessor of the aircraft is qualified business use

Carryover project.

446, 1275 and 6050H

Unspecified

Guidance to address the treatment and reporting of capitalized interest on modified home mortgages.

Carryover project.

451

Guidance

Regarding the treatment of deferred revenue in stock acquisitions

Carryover project.

New 451(b) and (c)

Unspecified

Definitional and other guidance.

New

453A

Regulations

Addressing contingent payment sales.

Carryover project from prior year.

468A

Final regulations

Involving the decommissioning costs of a nuclear power plant.

Carryover project from prior year.

472

Final regulations

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

Carryover project from prior year.

472

Regulations

Addressing dollar-value 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

Guidance

Addressing mark-to-market accounting.

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

861

Regulations and unspecified

Regarding the allocation and apportionment of interest expense, including guidance related to interest expense attributable to certain loans to related partnerships.

Carryover project.

861

Regulations

Addressing the character of income, including income arising in transactions involving intellectual property and the provision of digital goods and services.

Carryover project.

New 965

Notice

Guidance implementing new Section 965 and other international sections of the Act.

Notice 2018-07 released on December 29, 2017, and published in IRB 2018-04 on January 22, 2018.

301.9100

Unspecified

Guidance regarding relief for late regulatory elections

Carryover project.

Implications

Additional updates to the current Plan appear likely and will reflect an evolving approach as the Administration's tax reform efforts continue. Specifically, Treasury and the IRS have expressed an intent to periodically update the status of Plan projects and, for example, may add projects to respond to developments arising during the Plan Year.

It should be noted that at the Mid-Year ABA Tax meeting on February 9, 2018, government panelists indicated that definitional and other guidance will be issued to address new statutory revenue recognition provisions. Specifically, with regard to new Sections 451(b) and (c), the government is still evaluating the scope of issues to address.

As in the past, the Plan invites public comment regarding the development of the Plan and the guidance items listed.

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Contact Information
For additional information concerning this Alert, please contact:
 
National Tax Quantitative Services
Scott Mackay(202) 327-6069
Ken Beck(202) 327-7964
Alexa Claybon(303) 906-9721
Susan Grais(202) 327-8782
   • Any member of the Quantitative Services group, at (202) 327-6000.

Document ID: 2018-0308