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Weekly IRS Roundup April 17 – April 23, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 18, 2022: The IRS issued Revenue Ruling 2022-9, providing various prescribed interest rates for federal income tax purposes for May 2022.

April 18, 2022: The IRS issued a news release, reminding taxpayers of the option to request an automatic extension of time to file individual income tax returns and noting certain categories of taxpayers who automatically qualify for extensions.

April 18, 2022: The IRS issued a news release, setting forth certain penalty relief options that may be available to taxpayers who are unable to pay increased tax liabilities resulting from retroactive claims for employee retention tax credits.

April 19, 2022: The IRS issued Revenue Procedure 2022-23, providing procedures for taxpayers to make late elections under Sections 168(j)(8), 168(l)(3)(D) and 181(a)(1) of the Code, relating to certain depreciation deductions, for taxable years 2018 and 2019.

April 19, 2022: The IRS issued Notice 2022-16, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

April 19, 2022: The IRS issued a news release, announcing that the 2022 IRS Nationwide Tax Forum, an annual series of continuing education seminars for tax professionals, will be held virtually from July 19, 2022, through August 18, 2022.

April 19, 2022: The IRS issued a news release urging taxpayers who missed the April 18, 2022, filing deadline to file their individual tax returns as soon as possible in order to obtain tax refunds and limit penalties and interest.

April 20, 2022: The IRS issued a news release, announcing the awarding of more than $12.1 million in grants to 131 organizations across the country as part of its Low Income Taxpayer Clinic program, a program to assist organizations in providing pro bono representation to low-income and English as a second language (ESL) taxpayers in federal tax disputes.

April 21, 2022: The IRS issued a news release, reminding tax-exempt organizations of the May 16, 2022, filing deadline with respect to certain information and tax returns.

April 22, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.




Weekly IRS Roundup April 10 – April 16, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 10, 2022 – April 16, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 11, 2022: The IRS issued a news release, reminding taxpayers of the option to obtain an Identity Protection PIN to guard against tax-related identity theft.

April 12, 2022: The IRS issued a news release announcing the mailing of letters to certain taxpayers, notifying them of additional actions that must be taken to comply with the administrative requirements applicable to Qualified Opportunity Funds (QOFs).

April 12, 2022: The IRS issued a news release addressing certain common misconceptions regarding income tax refunds.

April 13, 2022: The IRS issued a news release, urging taxpayers who have filed their 2021 individual income tax returns to use the IRS Tax Withholding Estimator to ensure they are subject to an appropriate level of salary withholding for 2022.

April 13, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the 2020 Recovery Rebate Credit, enacted as part of the Coronavirus Aid, Relief and Economic Security (CARES) Act.

April 13, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the 2021 Recovery Rebate Credit, enacted as part of the American Rescue Plan Act of 2021 (ARPA).

April 14, 2022: The IRS issued a news release urging low- and moderate-income taxpayers to use IRS Free File to prepare and electronically file their tax returns.

April 14, 2022: The IRS issued a news release, reminding taxpayers of the resources available on irs.gov that can answer their tax questions.

April 15, 2022: The IRS issued Notice 2022-15, providing relief (for Q3 2022 through Q1 2023) with respect to penalties under Section 6656 of the Code for failure to make deposits of “Superfund” chemical taxes under Sections 4661 and 4671 of the Code, as reinstated by the Infrastructure Investment and Jobs Act (IIJA). The Notice also provides that, for Q1 2023 through Q3 2023, and subject to certain conditions, the IRS will not prohibit a taxpayer from using the Treas. Reg. § 40.6302(c)-1(b)(2)(v) “deposit safe harbor” if the taxpayer fails to make deposits of Superfund chemical taxes.

April 15, 2022: The IRS issued a news release, notifying taxpayers that CP2100 and CP2100A notices, which are sent semiannually to notify taxpayers who filed certain information returns that information on the returns does not match IRS records, will be sent out beginning in mid-April 2022.

April 15, 2022: The IRS issued a news release, reminding [...]

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Weekly IRS Roundup March 27 – April 2, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 29, 2022: The IRS issued a news release reminding taxpayers that the limitation on the educator expenses deduction of section 62(a)(2)(D) of the Code has risen from $250 to $300 for the 2022 taxable year.

March 29, 2022: The IRS issued a news release reminding taxpayers about, and providing information with respect to, filing extension options for individual income tax returns.

March 30, 2022: The IRS issued Revenue Procedure 2022-21, providing updates to the nationwide average purchase price for US residences and average purchase prices for different regional areas, for use in applying section 143 of the Code (relating to qualified mortgage bonds) and section 25 of the Code (relating to qualified mortgage credit certificates).

March 30, 2022: The IRS released Announcement 2022-07, providing the annual report on the Advance Pricing and Mutual Agreement Program and the advance pricing agreements (APAs) executed thereunder during calendar year 2021.

March 30, 2022: The IRS issued a news release providing various resources regarding claiming the 2021 Recovery Rebate Credit, as enacted by the American Rescue Plan Act of 2021 (ARPA).

March 31, 2022: The IRS issued a news release reminding taxpayers of the April 15, 2022 deadline for filing the Report of Foreign Banks and Financial Accounts (FBAR).

April 1, 2022: The IRS issued a news release announcing the appointment for 2022 of 25 new members to the Taxpayer Advocacy Panel, an advisory body that receives taxpayer feedback and makes suggestions for improving IRS customer service.

April 1, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our DC office for this week’s roundup.




Weekly IRS Roundup March 20 – March 26, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 20, 2022 – March 26, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 21, 2022: The IRS issued Revenue Ruling 2022-07, addressing the disclosure of tax information pursuant to certain exceptions to the general non-disclosure rule of Internal Revenue Code (Code) Section 6103(a). The Revenue Ruling, which modifies and supersedes Revenue Ruling 2004-53, generally holds that individuals who lawfully obtain tax information under the disclosure exception in Section 6103(c) of the Code are subject to restrictions on redisclosure. However, individuals who obtain tax information under the exceptions in Section 6103(e) or 6013(k)(6) of the Code are not subject to restrictions on redisclosure. The ruling further holds that these results are not affected by whether the individuals are government employees.

March 21, 2022: The IRS issued Notice 2022-14, providing guidance on various interest rates relevant to employee benefit plans under the Code.

March 22, 2022: The IRS issued a news release, providing tips to taxpayers on how to avoid common tax return filing mistakes.

March 22, 2022: The IRS issued a news release, reminding taxpayers of the various electronic payment and deferred payment options available to those who owe taxes with the filing of their individual income tax returns.

March 23, 2022: The IRS issued a news release, providing an update to a Fact Sheet that contains answers to frequently asked questions regarding the tax treatment of 2020 unemployment compensation, taking into account relief provided by the American Rescue Plan Act of 2021 (ARPA).

March 23, 2022: The IRS issued a news release, setting forth common reasons why certain tax refunds may take longer than 21 days to be issued.

March 25, 2022: The IRS issued proposed regulations, setting forth an exception to the “unified plan rule” for multiple employer plans (MEPs) under Section 413(c) of the Code.

March 25, 2022: The IRS issued Revenue Procedure 2022-15, providing an update to the rules taxpayers can use when generating substitutes for Form 941 (Employer’s Quarterly Federal Tax Return) and associated forms and schedules.

March 25, 2022: The IRS issued Revenue Procedure 2022-18, waiving the residence requirements needed to qualify for benefits under Section 911 of the Code for the 2021 taxable year, with respect to certain individual taxpayers who departed from Iraq, Burma, Chad, Afghanistan or Ethiopia in 2021.

March 25, 2022: The IRS issued a news release estimating that a total of nearly $1.5 billion worth of unclaimed tax refunds are available to approximately 1.5 million taxpayers who did not file individual income tax returns for the 2018 taxable year and urging those taxpayers to file such returns prior to the applicable deadlines in [...]

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IRS Proposes New Process for Post-Filing Disclosures to Replace Revenue Procedure 94-69

For many years, the Internal Revenue Service (IRS) has provided large corporate taxpayers who are under continuous audit to make affirmative disclosures at the start of an audit so they have an opportunity to disclose tax positions and avoid certain civil tax penalties. The procedure, outlined in Revenue Procedure 94-69, has been very popular with both taxpayers and IRS agents because it provides a mechanism that allows taxpayers to informally “amend” a return without filling out all of the paperwork. IRS agents also like the procedure because it allows them to focus the examination on the disclosed issues and incorporate the adjustments in the final computation from the audit. Indeed, the procedure has grown in practice to include the disclosure of affirmative and negative adjustments at the start of the examination and not just in the audits of taxpayers under the jurisdiction of the IRS’s Large Business & International division. However, as the continuous audit paradigm has ended, in 2020 the IRS questioned the continuing viability of this procedure and sought comments from taxpayers on if, and how, it should continue.

Numerous commentators (including the American Bar Association Section of Taxation and Tax Executives Institute, Inc.) recommended that the IRS keep this post-filing disclosure procedure in place, citing the following points in support:

  • The procedure avoids the need to file a formal amended return, a burdensome process on large taxpayers.
  • Requiring formal amended returns can be a significant strain on taxpayer resources, including the potential need to deal with state and local tax filings.
  • All mistakes can be fixed at one time (i.e., avoiding multiple amended returns).
  • The procedure eases reporting issues with Schedules K-1 that are issued after the original tax return is filed.
  • The procedure allows incorporating carryover adjustments from prior examinations.
  • There’s potential to avoid strict liability for penalties relating to transfer pricing adjustments.

On February 25, 2022, the IRS announced that it will standardize the process for making post-filing disclosures so that eligible taxpayers and IRS agents have consistent guidelines for determining what constitutes an adequate disclosure. To that end, the IRS has published a new draft form, Form 15307, Post-Filing Disclosure for Specified Large Business Taxpayers, to be used by eligible taxpayers seeking to make a post-filing disclosure. Taxpayer comments on the new draft form can be submitted here.

The draft Form 15307, which must be signed under penalties or perjury, requires that the taxpayer identify the number of disclosures and provide specific information about each disclosure, including:

  • Adjustment type
  • Timing
  • Effect of carryover
  • Description
  • Increase/decrease to taxable income or tax credits
  • Explanation of the item being disclosed

Examples of acceptable and unacceptable descriptions and disclosures are provided in the instructions to the draft form. Generally, netting of adjustments is not permitted, however, where the facts and circumstances of an item are identical and represent a high volume of low dollar amounts, the disclosures can be netted. The [...]

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Weekly IRS Roundup February 20 – February 26, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 20, 2022 – February 26, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

February 22, 2022: The IRS issued a correction to final regulations published on January 25, 2022, relating to the treatment of domestic partnerships that hold stock in foreign corporations.

February 22, 2022: The IRS issued a news release announcing the release of an updated list containing information about Low Income Taxpayer Clinics available around the country.

February 23, 2022: The IRS issued Revenue Ruling 2022-05 and an accompanying news release, setting forth the overpayment and underpayment interest rates under Section 6621 of the Code for Q2 2022.

February 24, 2022: The IRS issued final regulations relating to required minimum distributions under Section 401 of the Code with respect to certain employee pension and retirement plans.

February 24, 2022: The IRS issued a further correction to final regulations published on January 25, 2022, relating to the treatment of domestic partnerships that hold stock in foreign corporations.

February 24, 2022: The IRS issued a news release promoting its “Where’s My Refund?” online and mobile tools as ways for taxpayers to check on the status of their tax refunds.

February 24, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the Premium Tax Credit under Section 36B of the Code, as expanded by the American Rescue Plan Act of 2021 (ARPA).

February 25, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.




Weekly IRS Roundup February 13 – February 19, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2022 – February 19, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

February 14, 2022: The IRS issued a news release announcing the launch of a resource page that provides taxpayers with 2022 filing season updates, including updates concerning the resolution of unprocessed returns from the 2021 filing season.

February 15, 2022: The IRS issued Revenue Ruling 2022-4, providing various prescribed interest rates for federal income tax purposes for March 2022.

February 15, 2022: The IRS issued a news release announcing the release of an updated Form 14457, which relates to the IRS Voluntary Disclosure Practice for criminal prosecution. The updates include an expanded section on the reporting of virtual currency.

February 15, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the tax treatment of emergency grants for higher education, which were introduced pursuant to pandemic-related legislation.

February 16, 2022: The IRS issued a news release recommending that taxpayers use the online resources on its homepage as their first resource for tax inquiries and provided links to certain commonly used resources.

February 16, 2022: The IRS issued a news release, warning tax professionals to be alert for a new phishing scam designed to steal tax preparation software account credentials.

February 16, 2022: The IRS issued a news release, soliciting applications for Taxpayer Advocacy Panel membership, an advisory body that receives taxpayer feedback and makes suggestions for improving IRS customer service.

February 16, 2022: The IRS issued a news release, setting forth additional transition relief (in the form of an additional exception for certain taxpayers for tax year 2021) from the requirement to file the new Schedules K-2 and K-3 relating to partnerships and flow-through entities.

February 17, 2022: The IRS issued Notice 2022-09, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

February 17, 2022: The IRS issued a news release, reminding taxpayers with income from a farming or fishing business to file returns and pay taxes that are due by March 1, 2022, unless they have made estimated tax payments.

February 17, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the 2021 Recovery Rebate Credit, enacted as part of the American Rescue Plan Act of 2021 (ARPA).

February 18, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special [...]

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Weekly IRS Roundup February 6 – February 12, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 6, 2022 – February 12, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

February 7, 2022: The IRS issued a news release, announcing a transition away from using facial recognition technology to authenticate individuals seeking to create online IRS accounts.

February 8, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the 2021 Recovery Rebate Credit, enacted as part of the American Rescue Plan Act of 2021 (ARPA).

February 8, 2022: The IRS issued a news release and an associated Fact Sheet, urging taxpayers to file individual income tax returns for 2021—even if they are not required to do so—in order to take advantage of various tax benefits enacted by ARPA and other pandemic-related legislation.

February 9, 2022: The IRS issued a news release, announcing the release of the 2021 Annual Report for its Low Income Taxpayer Clinic (LITC) program.

February 9, 2022: The IRS issued a news release, announcing the suspension of several types of automated IRS correspondence, such as balance due notices and unfiled tax return notices, to alleviate administrative burdens during the 2021 filing season.

February 11, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.




Weekly IRS Roundup January 30 – February 5, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 30, 2022 – February 5, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

January 31, 2022: The IRS issued Revenue Procedure 2022-14, providing updates to the list of accounting method changes to which the automatic change procedures of Revenue Procedure 2015-33, as modified, apply.

January 31, 2022: The IRS issued a news release in advance of the 2021 filing season, providing a Fact Sheet that contains answers to frequently asked questions (FAQs) regarding the Child Tax Credit as expanded by the American Rescue Plan Act of 2021 (ARPA).

February 1, 2022: The IRS issued a news release, providing an update to the Fact Sheet released the previous day regarding the Child Tax Credit as expanded by ARPA.

February 1, 2022: The IRS issued a news release, setting forth certain administrative and logistical issues for taxpayers to consider in the process of filing an individual income tax return for 2021.

February 2, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to FAQs regarding the 2020 Recovery Rebate Credit, enacted as part of the Coronavirus Aid, Relief and Economic Security (CARES) Act.

February 3, 2022: The IRS issued a news release warning taxpayers to watch out for certain common tax scams and providing resources for victims of tax-related identity theft.

February 4, 2022: The IRS issued a news release announcing special Saturday hours at certain IRS Taxpayer Assistance Centers around the country to provide in-person assistance to taxpayers during the 2021 filing season.

February 4, 2022: The IRS issued an Action on Decision announcing its nonacquiescence to the holding in Quezada v. IRS, 982 F.3d 931 (5th Cir. 2020). The ruling held that the period of limitations on assessing backup withholding liability begins to run when the taxpayer files Forms 1040 and 1099-MISC that omit payee taxpayer identification numbers.

February 4, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.




National Taxpayer Advocate’s Report Highlights Tough Times for Tax Administration

On January 12, 2022, the National Taxpayer Advocate released a report to US Congress concerning the state of tax administration in 2021. The report highlights the struggles the Internal Revenue Service (IRS) has been having in the wake of the COVID-19 pandemic, including how the IRS is substantially behind in processing returns, the breakdown of the IRS call center, delays in processing responses to IRS notices sent to taxpayers and a myriad of other issues. (There is indeed a backlog for processing millions of tax returns!)

The Taxpayer Advocate Service (TAS) can be a helpful and powerful tool for taxpayers looking to resolve their tax issues with the IRS. We have provided information on this resource in earlier submissions. (See Taxpayer Advocate Service: Not Just for Low-Income Taxpayers.)

Practice Point: For those who are having difficulties interacting with the IRS and unable to achieve reasonable or satisfactory responses or explanations, seeking assistance from TAS can go a long way in resolving tax issues. The process is free to taxpayers and starts with the filing of Form 911 with the appropriate TAS office. If you seek assistance in the near future, be mindful that TAS is currently flooded with requests for help but will work your case—if it meets the relevant criteria—as soon as possible. A dose of patience will be needed to work through this resource to obtain a successful resolution of your tax issue.




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