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 that amplifies the guidance in Notice 2020-22, 2020-17 I.R.B. 664, which provides for penalty relief under section 6656 of the Code for an employer’s failure to timely deposit Employment Taxes with the IRS. This notice provides relief from section 6656 for employers required to pay qualified sick leave wages and qualified family leave wages, and qualified health plan expenses allocable to these wages, mandated by the Families First Coronavirus Response Act, as amended by the COVID-related Tax Relief Act of 2020, and the American Rescue Plan Act of 2021 (American Rescue Plan Act). This notice also provides relief from section 6656 for certain employers subject to a full or partial closure order due to COVID-19 or experiencing a statutorily specified decline in business under the Coronavirus Aid, Relief, and Economic Security Act, as amended by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 and the American Rescue Plan Act. Finally, this notice provides relief from section 6656 for certain employers for which COBRA continuation coverage premiums were not paid by assistance eligible individuals for such coverage by reason of section 9501(a)(1) of the American Rescue Plan Act.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2021 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2021, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv). In addition, it contains 24-month average segment rates for January 2020 through April 2021 determined under § 430(h)(2)(C)(iv) reflecting the modifications made by § 9706(a) of the American Rescue Plan Act of 2021.

The Opportunity Zone (“OZ”) provision allows taxpayers under certain circumstances to defer capital gain that they reinvest in qualified opportunity funds. These proposed regulations include requirements that certain foreign persons and certain foreign-owned partnerships must meet to defer their capital gains. The proposed regulations also allow, under certain circumstances, for the reduction or elimination of withholding tax under certain Code sections on the capital gain that is deferred under the OZ provision. In addition, these regulations provide flexibility for qualified opportunity zone businesses regarding the working capital safe harbor in the case of Federally declared disasters. REG-121095-19. Published [INSERT PUBLICATION DATE].

Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term tax exempt rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for May 2021.

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

This notice requests public recommendations for published guidance projects to be included on the 2021-2022 Priority Guidance Plan.