This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). This twenty-first report describes the experience, structure, and activities of the APMA Program during calendar year 2019.

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pamphlet form as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.

This notice provides tax relief under section 7508A of the Code for taxpayers affected by the Coronavirus Disease 2019 (COVID-19) emergency. The due date for certain Federal income tax payments due April 15, 2020, is postponed to July 15, 2020. Associated interest, additions to tax, and penalties for late payment will also be suspended until July 15, 2020. This notice is superseded by Notice 2020-18.

This notice supersedes Notice 2020-17 and provides tax relief under section 7508A of the Code for taxpayers affected by the Coronavirus Disease 2019 (COVID-19) emergency. The due date for filing Federal income tax returns and making Federal income tax payments due April 15, 2020, is postponed to July 15, 2020. Associated interest, additions to tax, and penalties for late payment will also be suspended until July 15, 2020.

This revenue procedure provides issuers of qualified mortgage bonds, as defined in section 143(a) of the Internal Revenue Code, and issuers of mortgage credit certificates, as defined in section 25(c), with (1) the nationwide average purchase price for residences located in the United States, and (2) average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam.

26 CFR 601.601: Rules and Regulations

(Also Part 1, §§ 143(e)(2), 6a.103A-2(f)(3), 6a.103A-2(f)(5).)

Federal rates; adjusted federal rates; adjusted federal long-term rate, the long-term exempt rate, and the blended annual rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for April 2020.

(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)

Fringe benefits aircraft valuation formula. For purposes of section 1.61-21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the first half of 2020 are set forth.

26 CFR 1.61-21: Taxation of fringe benefits.

The final regulations provide rules under section 901(m) for determining the amount of foreign taxes that are disqualified for foreign tax credit purposes with respect to certain covered asset acquisitions that result in a basis step-up for U.S. income tax purposes but not foreign tax purposes.

26 CFR 1.901(m)-1 through -8: Covered Asset Acquisitions

Notice 2020-19 withdraws Notice 2004-20, therefore removing the identification of transactions that are the same as, or substantially similar to, the transaction described in that notice as “listed transactions,” because the enactment of section 901(m) has curtailed the use of those transactions.