TAX CONTROVERSY 360

Weekly IRS Roundup September 30 – October 4, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Oct 15, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30, 2024 – October 4, 2024.

September 30, 2024: The IRS released Internal Revenue Bulletin 2024-40, which includes the following:

Revenue Ruling 2024-20, which provides the terminal charge and Standard Industry Fare Level mileage rates for valuing noncommercial flights on employer-provided aircraft for the second half of 2024.
Treasury Decision 9991, which contains final regulations that provide guidance on the consistent basis requirement under 1014(f) of the Internal Revenue Code (Code), applicable to recipients of certain property from a decedent, and the reporting requirements under Code § 6035, applicable to executors and other persons required to file an estate tax return. The final regulations adopt the 2016 proposed regulations (with some modifications) and are designed to ensure accurate reporting and compliance.
Proposed regulations, which amend the definition of “coverage month” to include any month where the premium paid, including advance payments, is sufficient to maintain an individual’s coverage from being terminated for that month when computing their premium tax credit (PTC). The proposed regulations also modify certain rules for calculating an individual taxpayer’s health insurance PTC and clarify eligibility criteria for state basic health programs.
Proposed regulations, which update the qualified domestic trust rules under Code 2056A by removing outdated references to align with current IRS procedures and revising filing requirements and addresses. The proposed regulations primarily affect estates passing property to noncitizen spouses.

September 30, 2024: The IRS released draft IRS Form 7217, Partner’s Report of Property Distributed by a Partnership, which requires partners to report property distributions from partnerships beginning in tax year 2024. Distributions consisting solely of money or marketable securities treated as money are excluded.

September 30, 2024: The IRS released Notice 2024-70, which extends the replacement period under Code § 1033(e) for livestock sold or exchanged because of drought conditions in specified counties across 41 US states, allowing more time for eligible farmers and ranchers to replace livestock.

October 1, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Illinois that were affected by severe weather that began on July 13, 2024. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in the following counties: Cook, Fulton, Henry, St. Clair, Washington, Will, and Winnebago.

October 1, 2024: The IRS announced it is seeking volunteers for the Volunteer Income Tax Assistance and Tax Counseling for the Elderly programs to provide free tax services during the upcoming filing season. Interested individuals can sign up from October to January, with flexible hours and various roles [...]

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Weekly IRS Roundup September 23 – September 27, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Oct 7, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23, 2024 – September 27, 2024.

September 23, 2024: The IRS released Internal Revenue Bulletin 2024-39, which includes the following:

Announcement 2024-39, which revokes the determination for specified organizations under § 501(c)(3) of the Internal Revenue Code (Code) and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).
Proposed regulations, which update and modify the 2017 proposed regulations, including the timing for making and revoking the proposed mark-to-market election and the Code § 954 currency elections. Taxpayers may rely on the regulations until they are finalized, but the changes to the 2017 proposed regulations take effect upon their publication in the Federal Register, which is expected on August 20, 2024.

September 23, 2024: The IRS announced the appointment of a new chief for its Independent Office of Appeals. They will be responsible for managing the resolution of tax disputes between taxpayers and the IRS without litigation.

September 24, 2024: The IRS released Revenue Procedure 2024-38, which provides guidance on the income requirements for qualified residential rental projects financed with exempt facility bonds under Code § Section 142(d) and for qualified low-income housing projects under Code § 42. The guidance will take effect on October 24, 2024.

September 26, 2024: The IRS introduced a supplemental claim process to assist payroll companies and third-party payers in resolving incorrect claims for the Employee Retention Credit. This process allows third-party payers to correct or withdraw claims for taxpayers who are ineligible for the credit.

September 26, 2024: The IRS released Revenue Ruling 2024-22, determining that the Bourse de Montréal (MX) is a qualified board or exchange under Code § 1256(g)(7)(C), provided it holds a valid Order of Registration from the Commodity Futures Trading Commission. This ruling is effective for MX contracts entered into on or after November 1, 2024.

September 27, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup September 16 – September 20, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 27, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16, 2024 – September 20, 2024.

September 16, 2024: The IRS released Internal Revenue Bulletin 2024-38, which include proposed regulations that detail the clean electricity low-income communities bonus credit program under § 48E of the Internal Revenue Code (Code). The regulations outline definitions, requirements, and procedures for applicants seeking to increase their clean electricity investment credit for the taxable year in which the facility is placed in service.

September 16, 2024: The IRS released Revenue Ruling 2024-21, which provides the October 2024 applicable federal rates.

September 17, 2024: The IRS appointed 10 new members to the Electronic Tax Administration Advisory Committee, which serves as a public forum for discussing electronic tax administration issues. These new members, which include state tax officials, cybersecurity experts, and tax professionals, bring diverse expertise from various fields.

September 17, 2024: The IRS recognized its Taxpayer Services Chief for their leadership and efforts to enhance taxpayer services and digital initiatives.

September 18, 2024: The IRS released proposed regulations, which provide a federal income tax credit of up to 30% for costs associated with installing qualified alternative fuel vehicle refueling property in low-income or non-urban census tracts under Code § 30C. The regulations outline eligibility criteria, application procedures, and specific requirements for claiming the credit.

September 18, 2024: The IRS released Notice 2024-64, which modifies Notice 2024-20 by updating the mapping tools used to identify eligible census tracts for the alternative fuel vehicle refueling property credit and extends the period during which taxpayers can rely on these tools. This notice is effective September 18, 2024.

September 18, 2024: The IRS released Notice 2024-67, which provides the 24-month average corporate bond segment rates for September 2024, the yield curve and segment rates for single-employer plans, and the 30-year Treasury securities interest rates.

September 18, 2024: The IRS released Revenue Procedure 2024-37, which provides guidance for issuers of tax-exempt and other tax-advantaged bonds on the procedures for filing claims to recover overpayments of rebate, the penalty in lieu of rebate provisions, and the yield reduction payment provisions under Code § 148. The guidance applies to claims filed on or after October 18, 2024.

September 18, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Pennsylvania that were affected by Tropical Storm Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency, including individuals and households that reside or have a business in Lycoming, Potter, Tioga and Union Counties.

September 19, 2024: The IRS announced it is offering a free webinar on September 26, [...]

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Weekly IRS Roundup September 9 – September 13, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 19, 2024 | IRS Audits, IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9, 2024 – September 13, 2024.

September 10, 2024: The IRS extended the deadline to file individual and business tax returns and make tax payments for certain individuals and businesses in Connecticut and New York that were affected by severe weather that began on August 18, 2024. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in Suffolk County in New York and in Fairfield, Litchfield, and New Haven Counties in Connecticut.

September 11, 2024: The IRS released an updated version of IRS Form 1099-DA and draft instructions for digital asset brokers to report sales and exchanges of digital assets beginning in 2025.

September 11, 2024: The IRS reminded taxpayers of their right to finality under the Taxpayer Bill of Rights and to know the deadlines for challenging IRS decisions and the time limits for the IRS to audit or collect taxes. This right ensures that taxpayers are aware when an audit is concluded and understand the specific timeframes for various tax-related actions.

September 12, 2024: The IRS released Notice 2024-66, which provides relief from the penalty under Internal Revenue Code (Code) § 6655 for underpayments of estimated corporate alternative minimum tax (CAMT) installments by corporations for taxable years beginning after December 31, 2023, and before January 1, 2025. This notice extends and incorporates relief from previous notices, offering additional time for corporations to meet their estimated tax obligations.

September 12, 2024: The IRS reminded taxpayers that the Taxpayer Advocate Service, an independent organization within the IRS, provides free assistance to individuals, businesses, and exempt organizations experiencing financial difficulties or systemic issues that cannot be resolved through standard IRS procedures.

September 13, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Louisiana that were affected by Tropical Storm Francine. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by FEMA, including individuals and households that reside or have a business in any Louisiana county.

September 13, 2024: The IRS released proposed regulations that outline the rules for calculating adjusted financial statement income and determining applicable corporation status under the CAMT for tax years starting after 2022. The proposed regulations provide additional guidance on partnership investments, corporate transactions, and foreign tax credits and extend penalty relief for corporations failing to pay estimated CAMT for tax years beginning after December 31, 2023, and before January 1, 2025.

September 13, 2024: The IRS released proposed regulations that exclude Tribal general welfare benefits from gross income under [...]

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Weekly IRS Roundup September 2 – September 6, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 13, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2, 2024 – September 6, 2024.

September 2, 2024: The IRS released Internal Revenue Bulletin 2024-36, which includes Notice 2024-63. The notice provides guidance on matching contributions for qualified student loan payments under § 401(k) of the Internal Revenue Code (Code) and other similar retirement plans. This guidance aims to help plan sponsors with setting up these programs for plan years beginning after December 31, 2024, until proposed regulations are issued.

September 3, 2024: The IRS reminded taxpayers to develop or update their emergency preparedness plans as part of National Preparedness Month, especially with the peak of hurricane season imminent and elevated wildfire risks. Key steps include protecting and duplicating essential documents, creating property inventories, and knowing how to reconstruct records if needed.

September 4, 2024: The IRS announced it is using funding from the Inflation Reduction Act of 2022 (IRA) to modernize taxpayer services with new online tools, including the IRS Energy Credits Online platform, which simplifies the process for claiming clean energy credits. These improvements aim to save taxpayers time and money while enhancing compliance and fraud mitigation.

September 4, 2024: The IRS released Revenue Procedure 2024-34, which modifies Revenue Procedure 2024-23 to provide procedures under Code § 446 for obtaining automatic consent to change accounting methods for Code § 174 research or experimental expenditures paid or incurred after December 31, 2021. The new revenue procedure also limits audit protection for these expenditures if changes are not made in the applicable tax year.

September 4, 2024: The IRS reminded tax professionals to be vigilant for signs of data breaches, such as slow computer performance, unexpected cursor movements, and clients receiving IRS authentication letters for returns they did not file. Immediate reporting to the IRS and proactive measures, such as obtaining an Identity Protection PIN, are crucial to mitigate the impact of data theft.

September 5, 2024: The IRS encouraged taxpayers to use Identity Protection PINs and establish an IRS online account to safeguard against identity theft and fraud. These tools help protect personal and financial information from being stolen by scammers.

September 5, 2024: The IRS reminded taxpayers that the deadline for the third quarter estimated tax payment is September 16, 2024. Taxpayers in disaster-affected areas in 17 US states, Puerto Rico, and the Virgin Islands may qualify for an extended deadline.

September 5, 2024: The IRS released Notice 2024-65, requesting public comments on the implementation of Saver’s Match contributions, a new initiative under Code § 6433 aimed at boosting retirement savings for low-to-moderate-income individuals. Public comments are sought on various aspects, including eligibility, claiming processes, and outreach to traditionally marginalized communities, with a deadline of November 4, 2024.

September 6, 2024: The IRS announced [...]

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