ABA Submits Recommendations for IRS, Treasury 2018-19 Guidance Plan

The American Bankers Association today wrote to the Internal Revenue Service outlining several key issues that the IRS and the Treasury Department should include in their 2018-2019 Priority Guidance Plan. The plan is intended to help identify and prioritize tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.

ABA recommended that the IRS and Treasury add several tax reform-related items to the plan, including the application of Section 199A to banks operating as pass-through entities; the application of Section 965, which addresses tax for trusts and estates; treatment of estate, gift and generation-skipping transfer taxes after the provision sunsets in 2026; and deductions allowed under Section 67(e).

In addition, the association urged IRS and Treasury to continue their work on the appropriate treatment and reporting of accrued but unpaid interest on modified mortgages; guidance under Section 166 addressing the conclusive presumption of worthlessness for debts; and final rules on the consistent basis reporting of an estate’s assets and changes to Form 8971. ABA also recommended that the guidance plan include a suggested amendment to form 1041. For more information, contact ABA’s John Kinsella or Phoebe Papageorgiou.