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October 13,  2008

Federal Headlines


IRS Released Guidance on Filing Amended Returns for Hurricane-Related Grants (IR-2008-115; Notice 2008-95)

 

The IRS has released a notice informing eligible homeowners, who received federal grants for damages to or destruction of homes caused by Hurricanes Katrina, Rita or Wilma, how to file an amended return to take advantage of section 3082(a) of the Housing and Economic Recover Act of 2008 (P.L. 110-289). The new provision allows eligible taxpayers to elect to file an amended return to reduce previously taken casualty losses in a later year.

 

Taxpayers should use Form 1040X, Amended U.S. Individual Income Tax Return, to amend prior-year returns to reduce the casualty loss deduction by the amount of the grant. The words, "Hurricane Grant Relief" in dark, bold letters should be written at the top of Form 1040X, which should be mailed to: Internal Revenue Service Center, Austin, TX 73301-0255. Amended returns cannot be filed electronically.

 

To qualify for this relief, amended returns must be filed by July 30, 2009, together with the proof of amount of any hurricane relief grant received and a completed Form 2848, Power of Attorney and Declaration of Representative, if a taxpayer designates a representative. The balance due on the amended return must be paid within one year of the timely filing of the amended return to avoid interest and penalties. Payments made subsequent to the filing of the amended return should clearly designate that the payment is to be applied to reduce the balance due on the amended return.

 

Taxpayers who have already filed an amended return must send a copy of the previously filed Form 1040X, or submit Form 843, to the IRS at the same address above. Either form should include the taxpayer's contact information and a power of attorney, if applicable. Copies of the original return for the year of the casualty loss deduction and any amended returns for that year filed prior to the publication of this notice and copies of the original and amended returns for the year of receipt of the grant if any portion of the grant was previously reported as income in the year of receipt must also be submitted. These documents must be sent by the later of the due date for the return for the year in which the hurricane relief was granted, as extended, or July 30, 2009.

 

Taxpayers are not required to amend a prior year's return and may, instead, include the hurricane relief grants in gross income in the year the grant was received up to the amount of tax reduced by the casualty loss deduction pursuant to Reg. §1.165-1(d)(2)(iii). The IRS cautioned that, although filing an amended return may be a good option for many, it is not necessarily the right choice for all affected taxpayers. The IRS encourages affected taxpayers and their representatives to consider carefully the option that is best under their particular circumstances.

IR-2008-115,

2008FED ¶46,612

Notice 2008-95, 2008FED ¶46,613

Other References:

 

Code Sec. 165

 

CCH Reference - 2008FED ¶10,005.073

 

CCH Reference - 2008FED ¶10,005.16

 

Tax Research Consultant

 

CCH Reference - TRC INDIV: 54,302


IRS Issues Application Procedures for 2008-2009 Advanced Coal Project Credit Allocation Round (Notice 2008-96)

 

The IRS has updated procedures for the allocation of credits under the qualifying advanced coal project program relating to the qualifying advanced coal project credit under Code Sec. 48A. The notice provides that, except as specifically provided, the allocation round for 2008-09 will be conducted in the same manner and under the same procedures as provided under Notice 2007-52, I.R.B. 2007-26, 1456, for the 2007-2008 round of allocations. Applications for the 2008-2009 allocation round must be submitted to the Department of Energy on or before October 31, 2008, and to the IRS on or before March 2, 2009.

 

The updated notice treats March 13, 2006, as the date on which the qualifying advanced coal project program was established and as the first day of the three-year period during which applications must be submitted as required by Code Sec. 48A(d)(2)(A). Also, applicants are now required to submit both an electronic and paper copy of the documentation establishing that the requirements for certification have been met.

 

This latest guidance does not reflect amendments made to Code Sec. 48A by the Emergency Economic Stabilization Act of 2008 (P.L. 110-343)). The new law increases the credit rate to 30 percent and authorizes the IRS to allocate an additional $1.25 billion in credits to qualified projects that separate and sequester at least 65 percent of total carbon dioxide emissions. The IRS intends to issue future guidance on these changes in the near future.

Notice 2008-96, 2008FED ¶46,614

Other References:

 

Code Sec. 48A

 

CCH Reference - 2008FED ¶4675.021

 

CCH Reference - 2008FED ¶4675.029

 

CCH Reference - 2008FED ¶4675.15

 

Tax Research Consultant

 

CCH Reference - TRC BUSEXP: 51,702.05

 

CCH Reference - TRC BUSEXP: 51,704

 

CCH Reference - TRC BUSEXP: 51,704.05

 

CCH Reference - TRC BUSEXP: 51,704.10

 

CCH Reference - TRC BUSEXP: 51,704.15

 

CCH Reference - TRC BUSEXP: 51,704.20

 

CCH Reference - TRC BUSEXP: 51,704.25

 

CCH Reference - TRC BUSEXP: 51,708


Effective Date of Regulations Governing Retirement Age Postponed for Governmental Plans (Notice 2008-98)

 

The IRS and the Treasury Department intend to amend Reg. §1.401(a)-1(b)(4) to extend the date by which a governmental plan must comply with rules governing pension plan distributions upon attainment of normal retirement age. As issued in 2007, these regulations were to be effective for governmental plan years beginning on or after January 1, 2009. As amended, the regulations will be effective for plan years beginning on or after January 1, 2011. Governmental plan sponsors may rely on this notice until the regulations are amended.

 

The 2007 regulations provide that a pension plan's normal retirement age must not be earlier than the earliest age that is reasonably representative of the typical retirement age for the industry in which the covered workforce is employed. Generally, a normal retirement age of 62 or later (or 50 or later if substantially all the plan participants are qualified public safety employees) is deemed to satisfy this requirement; a normal retirement age lower than 55 is presumed not to satisfy the requirement, and facts and circumstances determine whether any other normal retirement age satisfies the requirement. Notice 2007-69, 2007- 2 CB 468, provided temporary relief for certain plans that may have to change their definition of normal retirement age, but the relief did not apply to governmental plans.

Notice 2008-98, 2008FED ¶46,616

Other References:

 

Code Sec. 401

 

CCH Reference - 2008FED ¶17,505

 

CCH Reference - 2008FED ¶17,508.129

 

Tax Research Consultant

 

CCH Reference - TRC RETIRE: 15,056


Guidance Provided on Election Not to Claim 50-Percent Additional First-Year Depreciation (Rev. Proc. 2008-65)

 

The IRS has provided guidance to clarify the rules regarding the effects of making the Code Sec. 168(k)(4) election not to claim bonus depreciation, the property eligible for the election, and the computation of the amount by which the business credit limitation and alternative minimum tax (AMT) credit limitation may be increased if the election is made. Except for certain automotive partnerships, only a corporation may elect to apply Code Sec. 168(k)(4). The election is made by the taxpayer for its first tax year ending after March 31, 2008, and applies to all eligible qualified property placed in service by the taxpayer in the taxpayer's first tax year ending after March 31, 2008, and in any subsequent tax year.

 

Several requirements must be met for qualified depreciable property to be eligible qualified property under Code Sec. 168(k)(4). Among those requirements are: (1) original use of the property must commence with the taxpayer after March 31, 2008, and (2) for a taxpayer manufacturing, constructing, or producing property for the taxpayer's own use, the taxpayer must begin manufacturing, constructing, or producing the property after March 31, 2008, and before January 1, 2009. If the election is made, the straight-line depreciation method must be used for all eligible qualified property.

Rev. Proc. 2008-65, 2008FED ¶46,617

Other References:

 

Code Sec. 168

 

CCH Reference - 2008FED ¶11,279.058

 

Tax Research Consultant

 

CCH Reference - TRC DEPR: 3,600


State Headlines


New Mexico --Multiple Taxes: TRD Grants Hurricane-Related Tax Extensions

 

The New Mexico Taxation and Revenue Department (TRD) announced that filing due dates have been extended for New Mexico personal income, corporate income, gross receipts, compensating, and withholding taxes until January 5, 2009, for taxpayers affected by Hurricanes Ike and Gustav. The extension only applies to filing due dates; it does not extend the time to pay any associated tax. Therefore, the TRD will waive penalties for late returns, but interest will still be imposed on late payments of tax.

 

Only taxpayers who reside or maintain a business location in the areas authorized by the IRS in IRS News Releases IR-2008-108, IR-2008-100, and IR-2008-107 qualify for the New Mexico extension. Affected taxpayers taking advantage of the state extension are required to write "Texas/Hurricane Ike," "Louisiana/Hurricane Ike," or "Louisiana/Hurricane Gustav" (as appropriate) at the top of their return.

 

Subscribers to CCH Tax Research NetWork can view the TRD's release.

Release, New Mexico Taxation and Revenue Department, October 10, 2008.

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