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IRS roundup: December 12, 2025 – January 12, 2026

by and | Jan 13, 2026 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026.

December 12, 2025: The IRS issued Treasury Decision 10042, which modified and clarified the Internal Revenue Code (Code) Section 892 rules. The Treasury Decision contains final regulations regarding the taxation of income earned by foreign governments from investments in the United States. The regulations clarify how to determine when a foreign government is engaged in commercial activity and when an entity qualifies as a controlled commercial entity. These rules apply to foreign governments that earn income from US sources.

December 12, 2025: The IRS issued proposed regulations, which provided additional guidance under Section 892 and focus on:

  • Determining when an acquisition of debt by a foreign government is treated as a commercial activity
  • Determining when a foreign government has effective control of an entity engaged in a commercial activity
  • Clarifying that partnerships, including partnerships wholly owned by a single foreign sovereign, are not controlled entities under Section 892 for US tax purposes.

December 15, 2025: The IRS issued proposed regulations, updating points of contact within the US Department of Justice (DOJ) and the IRS to identify points of contact for matters involving internal revenue laws following a reorganization within the DOJ. The regulations would also update points of contact at the IRS for taxpayers submitting administrative claims for civil damages related to certain unauthorized collection actions or awards of administrative costs in specified administrative proceedings.

December 15, 2025: The IRS withdrew two notices of proposed rulemaking regarding innocent spouse relief.

December 22, 2025: The IRS issued proposed updates, which set forth a clearer, more predictable system for its Voluntary Disclosure Practice and a more streamlined penalty framework. The IRS seeks public comment on the proposed updates by March 22, 2026.

December 29, 2025: The IRS released Internal Revenue Bulletin 2026-1, which includes the following:

  • Revenue Procedure 2026-1, which contains the revised procedures for letter rulings and information letters issued by the different associate chief counsel offices. This revenue procedure also contains the revised procedures for determination letters issued by the Large Business and International Division, the Small Business/Self-Employed Division, the Wage and Investment Division, and the Tax Exempt & Government Entities (TE/GE) Division.
  • Revenue Procedure 2026-2, which explains when and how associate chief counsel offices should provide advice in technical advice memoranda (TAM) as well as taxpayers’ rights when a field office requests a TAM.
  • Revenue Procedure 2026-3, which provides a revised list of Code areas under the jurisdiction of the following associate chief counsel offices:
    • Corporate
    • Financial Institutions and Products
    • Income Tax and Accounting
    • Passthroughs and Special Industries
    • Procedure and Administration
    • Energy, Credits, and Excise Tax
    • Employee Benefits, Exempt Organizations, and Employment Taxes.

These relate to matters in which the IRS will not issue letter rulings [...]

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IRS roundup: December 15 – December 22, 2025

by and | Jan 6, 2026 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 15, 2025 – December 22, 2025. 

December 15, 2025: The IRS issued Notice 2026-2, providing an update on weighted average interest rates, yield curves, and segment rates. The notice specifically focused on the corporate bond monthly yield curve, corresponding spot segment rates used for purposes of Internal Revenue Code (Code) Section 417(e)(3), and 24-month average segment rates for purposes of Code Section 430(h)(2). Notice 2026-2 also provides the interest rate for 30-year Treasury securities for purposes of Code Section 417(e)(3)(A)(ii)(II), as in effect for plan years beginning before 2008, as well as the 30-year Treasury weighted average rate for purposes of Code Section 431(c)(6)(E)(ii)(I).

December 15, 2025: The IRS issued Revenue Ruling 2026-2, providing various prescribed rates for federal income tax purposes for January 2026. The prescribed rates include:

  • Short-, mid-, and long-term applicable federal rates for certain debt instruments in the Code.
  • Section 42(b)(1) housing credit appropriate percentages.
  • The deemed rate of return for calendar year 2026 transfers made to pooled income funds, as described in Section 642(c)(5).
  • The average of the applicable federal mid-term rates for the 60-month period ending December 31, 2025.

December 19, 2025: The IRS issued Notice 2026-1, providing interim guidance related to the credit for carbon oxide sequestration under Code Section 45Q pending the forthcoming proposed regulations removing reporting obligations related to the geological sequestration of carbon dioxide imposed under subpart RR of 40 CFR part 98. The notice specifically provides a safe harbor for determining eligibility for qualified carbon oxide, captured and disposed of in secure geological storage and not used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project, during calendar year 2025. Notice 2026-1’s safe harbor applies if the US Environmental Protection Agency does not launch the electronic Greenhouse Gas Reporting Tool for filers to prepare and submit information required under subpart RR by June 10, 2026. Taxpayers can rely on the safe harbor to demonstrate compliance with subpart RR requirements when determining the Code Section 45Q credit related to the 2025 Calendar Year Secure Geological Storage.

December 19, 2025: The IRS issued Notice 2026-6, extending the transition period in Revenue Ruling 2025-4 for states administering paid family and medical leave (PFML) programs and employers participating in PFML programs. The extension is for an additional year and only as it relates to the medical leave benefits a state pays to an individual that can be attributed to employer contributions.

December 22, 2025: The IRS issued Notice 2026-3, providing relief from Code Section 6654 and 6655 additions of tax for underpayments of estimated income tax by taxpayers making valid Code Section 1062(a) elections.

December 22, 2025: In Announcement 2026-1, the IRS declared its intent to issue guidance related to Code Section 6435. That guidance, intended for taxpayers that paid Code [...]

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Potential refund opportunity of buyback excise tax based on § 4501 final regulations

by , , , and | Dec 15, 2025 | ,

Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in the recently issued IRC § 4501 final regulations.

On November 21, 2025, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under IRC § 4501, which took effect on November 24 and significantly narrowed the applicability of the stock repurchase excise tax compared to prior guidance provided in Notice 2023‑2 and the April 9, 2024, proposed regulations (collectively, the prior guidance). As a result, many transactions that were previously treated by the prior guidance as “repurchases” subject to the 1% stock repurchase excise tax are now no longer taxable. Taxpayers who paid the excise tax based on the prior guidance may be eligible for a refund.

The final regulations eliminated the prior guidance’s broad “funding rule,” which treated a US affiliate that was considered to have “funded” a foreign publicly traded parent (or its foreign affiliates), including via distributions or capital contributions, as having engaged in a covered stock repurchase. The final regulations also significantly narrowed the proposed regulations’ expansive treatment of transactions as “economically similar” to a stock repurchase by specifically excluding leveraged buyouts and other take-private transactions, complete liquidations, and tax-free acquisitive reorganizations under IRC § 368 from being subject to the excise tax. Moreover, the final regulations narrowed what qualifies as “stock” for IRC § 4501 purposes, specifically excluding certain preferred stock described in IRC § 1504(a)(4) (e.g., “plain vanilla” non-voting, non-participating preferred stock) and certain mandatorily redeemable or puttable stock issued before August 16, 2022 (i.e., the date of enactment of IRC § 4501).

The changes in the final regulations have potentially sweeping implications for taxpayers who paid the IRC § 4501 stock repurchase excise tax based on the prior guidance. The narrower scope of the applicability of stock repurchase excise tax under the final regulations creates a substantial opportunity to seek a refund of stock repurchase excise tax previously paid under the now-obsolete prior guidance.

To seek a refund, taxpayers should file Form 720-X, Amended Quarterly Federal Excise Tax Return, for each quarter they filed an original Form 720 reporting and paid the stock repurchase excise tax and attach a Form 7208 (with “Amended” at the top of each form) to each quarterly Form 720-X. Both Form 720-X and amended Form 7208 should be completed, and the excise tax recomputed, based on the final regulations. Because Form 720-X will serve as the taxpayer’s refund claim, it is critical that Form 720-X contains a detailed explanation of the legal basis for the adjustments to the original Forms 720 and 7208 to meet regulatory requirements imposed by the Treasury on refund claims. See Treas. Reg. § 301.6402-2 (setting forth the basic requirements for refund claims).

Taxpayers considering this refund opportunity should be aware that the statute of limitations deadline for filing a refund [...]

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Major update: Potential refund opportunity for interest and penalty amounts accrued during COVID-19 federally declared disaster

by and | Dec 8, 2025 | , , , , , ,

The US Court of Federal Claims’ (CFC) recent decision in Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025), provides significant support for the potential refund opportunity we identified in a previous blog post titled, “Refund opportunity for interest and penalty amounts accrued during COVID-19 federally declared disaster.” The refund opportunity applies to taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/failure-to-pay penalties that accrued during all or part of the period from January 20, 2020, through July 10, 2023.

Although the CFC’s holding in Kwong addressed whether Internal Revenue Code (IRC) § 7508A provided the taxpayer an extension of the two-year statute of limitations deadline for filing a refund suit (in IRC § 6532(a)) that fell after the COVID-19 disaster was declared, Kwong answered important questions for those taxpayers pursuing refunds for underpayment interest and/or failure-to-file/failure-to-pay penalties that accrued during COVID-19. The CFC held that the 2019 version of IRC § 7508A applies to the COVID-19 federally declared disaster. This is a significant holding because Congress amended IRC § 7508A in 2021 to significantly limit the IRC § 7508A(d) mandatory extension period. The CFC also held that the IRC § 7508A(d) mandatory extension period, as applied to the COVID-19 disaster, commenced on January 20, 2020, and ended on July 10, 2023.

Kwong has potentially sweeping implications for taxpayers who faced federal tax filing and/or payment deadlines that fell between January 20, 2020, and July 10, 2023. Under the CFC’s Kwong analysis, the deadline for payment of any federal tax falling between these two dates was extended to July 11, 2023. Since the IRS computes underpayment interest and/or failure-to-file/pay penalties from the payment due date, penalties should not accrue from January 20, 2020, through July 10, 2023, and any taxpayers who already paid these amounts may be entitled to a refund. The CFC’s analysis also does not rule out the possibility that taxpayers with payment due dates preceding January 20, 2020, may be entitled to relief to the extent the underpayment interest and/or failure-to-file/failure-to-pay penalties accrued during the COVID-19 disaster period.

As noted in our previous post, taxpayers considering this refund opportunity should be aware that the statute of limitations to file a refund claim expires three years from the filing deadline of the original tax return or two years from the date on which payment was made, whichever is later (unless the statute of limitations period was otherwise extended). This refund opportunity may apply to underpayment interest and/or penalties paid with respect to federal income, estate, gift, employment, or excise taxes.



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IRS roundup: November 7 – November 24, 2025

by , , , , and | Dec 2, 2025 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 7, 2025 – November 24, 2025.

November 10, 2025: The IRS released Internal Revenue Bulletin No. 2025-46, which includes proposed regulations 109742-25. The proposed regulations would remove a rule in previous final regulations that uses the shareholders of certain domestic corporations to determine whether foreign persons hold – directly or indirectly – stock in a domestically controlled qualified investment entity (QIE). If a QIE was not domestically controlled following the changes from the proposed regulations, stock owned by foreign persons in a QIE would qualify as a US real property interest.

November 10, 2025: The IRS released Revenue Procedure 2025-31, providing guidance on a safe harbor that allows trusts qualifying as investment trusts under Section 301.7701-4(c) and as grantor trusts to stake digital assets without losing their tax status and offering a limited period for existing trusts to amend their governing instruments to meet the safe harbor requirements.

November 13, 2025: The IRS released Notice 2025-67, which announces the annual cost-of-living adjustments to the limits on benefits and contributions for qualified retirement plans under Section 415 of the Internal Revenue Code (Code). These adjustments, required by Section 415(d), follow procedures similar to those used for Social Security benefit updates and apply to certain amounts under deferred compensation plans.

November 13, 2025: The IRS released Revenue Ruling 2025-22, announcing that interest rates will remain unchanged for the calendar quarter beginning January 1, 2026. The rates are as follows:

  • 7% for individual overpayments and 6% for corporate overpayments
  • 5% on the portion of a corporate overpayment exceeding $10,000
  • 7% for underpayments and 9% for large corporate underpayments

Under the Code, these rates are recalculated quarterly based on the federal short-term rate. For noncorporate taxpayers, both overpayment and underpayment rates equal the federal short-term rate plus three percentage points. For corporations, the underpayment rate is also the short-term rate plus three points while the overpayment rate is the short-term rate plus two points. Large corporate underpayments add five points, and corporate overpayments exceeding $10,000 add 0.5 points. The current rates are based on the federal short-term rate determined in October 2025.

November 19, 2025: The IRS announced that it would resume its regular activities following the 2025 lapse in appropriations during the government shutdown. In its announcement, the IRS included specific frequently asked questions regarding the resumption of regular activities for audits, collections, and appeals and stated that determination letter applications for tax exempt and government entities would resume.

Recent court decisions

November 5, 2025: The US District Court for the Northern District of Texas issued an opinion in Ryan, LLC v. IRS. Check out our recent insight on the case, including an analysis of the district court’s holdings and practice points for taxpayers.

November 12, 2025: The US [...]

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Tax consulting firm permitted to challenge final micro-captive reporting regulations

by and | Dec 2, 2025 | , ,

Ryan, LLC v. Internal Revenue Service[1] is the latest example of success in overcoming procedural hurdles to challenge the validity of a US Department of the Treasury (Treasury) regulation. In a recent opinion, the US District Court for the Northern District of Texas held that:

  • Ryan has standing to challenge the validity of the Treasury’s final regulations[2] that require disclosure of certain transactions engaged in by businesses and their “micro-captive insurance companies” (MCICs).
  • Ryan sufficiently pleaded its claim that the final regulations under challenge were “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” and must be set aside under the Administrative Procedure Act (APA).[3]
  • The court’s opinion confirms that nontaxpayer actors may have standing to challenge Treasury regulations. The case is also another example of a plaintiff reaching the merits stage of a challenge to a Treasury regulation in the aftermath of Loper Bright v. Raimondo.[4]

Background

Ryan is an advisor to businesses seeking to establish and maintain MCICs. “Captive” insurance companies are specialized insurance companies that exist to insure the entities that own them. When the owning entities make premium payments to the captive, the premiums do not need to include commissions or other fees associated with traditional insurers, making captives an attractive option especially when coverage is unavailable or costly through traditional insurers. Certain small captive insurance companies, commonly called MCICs, qualify for favorable tax treatment. Under section 831(b), MCICs are not taxed on the first $2.2 million in premiums paid by their owner-insured. The Internal Revenue Service (IRS) has increased its scrutiny of the captive insurance industry because of concerns that these arrangements may be exploited for fraud and abuse.

The Treasury’s new regulations

Section 6707A requires the disclosure of certain “reportable transactions,” defined as transactions that, in the IRS’s determination, have a “potential for tax avoidance or evasion.” A “listed transaction” is a type of reportable transaction in which the taxpayer is presumed to have engaged in the transaction for the purpose of tax avoidance or evasion.[5] A “transaction of interest” is a reportable transaction designated by the IRS as having a potential for abuse but is not presumed abusive.[6] These designations create heavy reporting requirements by taxpayers and their advisors (e.g., Ryan).

Under the Treasury’s new regulations, a micro-captive insurance transaction is defined based on a loss ratio factor and a financing factor. The loss ratio factor is the ratio of the captive insurance company’s cumulative insured losses to the cumulative premiums earned over a specified period, typically the most recent 10 taxable years (or all years if less than 10). The financing factor refers to whether the captive insurance company participated in certain related-party financing arrangements within the most recent five taxable years, such as making loans or other transfers of funds to insureds, owners, or related parties. A transaction is classified as a “listed transaction” if the MCIC’s loss ratio is [...]

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Tax Court confirms codified economic substance doctrine requires threshold relevancy determination, upholds 40% strict-liability penalty

by and | Nov 24, 2025 | , ,

Patel v. Commissioner, 165 T.C. No. 10 (Nov. 12, 2025), gave the US Tax Court its “first opportunity to examine when the codified economic substance doctrine applies.” Patel at *16. The Tax Court made two key holdings:

  • Section 7701(o) requires a relevancy determination that “is not coextensive with the two-part test set forth in section 7701(o)(1)(A) and (B).” Patel at *17.
  • Adequate disclosure to reduce the 40% economic substance penalty imposed by sections 6662(b)(6) and (i) must be made at the time the return is filed and not at a later time. Patel at *30.

Relevancy determination

Section 7701(o) provides:

Sec. 7701(o). Clarification of economic substance doctrine.—

 

(1) Application of doctrine.—In the case of any transaction to which the economic substance doctrine is relevant, such transaction shall be treated as having economic substance only if—

 

(A) the transaction changes in a meaningful way (apart from Federal income tax effects) the taxpayer’s economic position, and

 

(B) the taxpayer has a substantial purpose (apart from Federal income tax effects) for entering into such transaction.

While the Internal Revenue Service (IRS) endorses a seemingly limitless application of the codified economic substance doctrine, taxpayers contend that it does not apply to every transaction. Rather, the plain language of section 7701(o)(1) requires a threshold relevancy determination. If the economic substance doctrine is not relevant, the inquiry ends.

There are very few cases that have considered whether section 7701(o) requires a threshold relevancy determination. And those that have found that section 7701(o) does not impose a separate relevancy requirement. See Liberty Global, Inc. v. United States, No. 20-cv-63501, 2023 WL 8062792 (D. Colo. Oct. 31, 2023); Chemoil Corp. v. United States, No. 19-cv-6314, 2023 WL 6257928 (S.D.N.Y. Sept. 26, 2023). While Liberty Global was appealed to the US Court of Appeals for the Tenth Circuit – and many speculate the Tenth Circuit may clarify that there is a relevancy requirement – the Tax Court beat the appellate court to the punch.

The Tax Court’s holding had solid statutory support. The plain language of section 7701(o)(1) states: “In the case of any transaction to which the economic substance doctrine is relevant…” After quoting these words, the Tax Court stated, “we easily conclude that the statute requires a relevancy determination. To put it plainly—the statute says so, right there, on its face.” Patel at *17.

Adequate disclosure of transactions

The second key holding in Patel is that the taxpayers in the case are liable for a 40% penalty for engaging in a transaction that lacks economic substance that was not adequately disclosed. Section 6662(b)(6) imposes a 20% penalty on transactions that lack economic substance. This penalty is increased to 40% under section 6662(i) if the transaction is not adequately disclosed.[1]

In the current wave of economic substance challenges, it is unclear what constitutes adequate disclosure under section 6662(i) such that the 20% (instead of the 40%) penalty applies. Based on current audit activity, [...]

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IRS roundup: October 23 – November 6, 2025

by , , , , and | Nov 7, 2025 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 23, 2025 – November 6, 2025.

October 23, 2025: The IRS issued frequently asked questions, addressing its revisions and updates to Form 1099-K following changes resulting from the One Big Beautiful Bill Act (OBBBA). The OBBBA retroactively reinstated the reporting threshold in effect prior to the passage of the American Rescue Plan Act of 2021 (ARPA). This means that a third-party settlement organization (TPSO), which is a type of payment settlement entity, is generally not required to file a Form 1099-K. However, TPSOs will be required to file a Form 1099-K if the gross amount of reportable payment transactions to a payee exceeds $20,000 and if the number of reportable payment transactions exceeds 200. Previously, under the ARPA reporting threshold, TPSOs had to file a Form 1099-K for any payee that received more than $600 in total payments for the sales of goods or services, regardless of the number of reportable payment transactions.

October 27, 2025: The IRS reminded tax preparers that preparer tax identification numbers (PTINs) must be renewed annually and that the 2026 renewal period is now open. All 2025 PTINs will expire on December 31, 2025.

November 3, 2025: The IRS released Internal Revenue Bulletin No. 2025-45, which includes Notice 2025-61. Notice 2025-61 provides guidance on the adjusted applicable dollar amount for the Patient-Centered Outcomes Research Trust Fund (PCORTF) fee, which is imposed on issuers of specified health plans and plan sponsors of applicable self-insured health plans to fund PCORTF. Notice 2025-61 specifically provides the increased adjusted applicable dollar amount for determining the PCORTF fee as $3.84 (from the previous set amount of $3.47) for all policies and plans ending on or after October 1, 2025, and before October 1, 2026. The IRS explained that the amount was calculated by US Department of the Treasury economists based on the percentage increase in the projected per capita amount of National Health Expenditures, which was published by the US Department of Health and Human Services in June 2025.

November 5, 2025: The IRS issued Notice 2025-62, providing guidance on penalty relief for taxable year 2025 in connection with the implementation of new information reporting requirements related to the deductions for qualified tips and qualified overtime compensation to reflect amendments resulting from the OBBBA. Notice 2025-62 specifically provides relief for taxable year 2025 from the penalty under Section 6721 for failure to file correct information returns and the penalty under Section 6722 for failure to furnish correct payee statements. The IRS also announced that guidance on how taxpayers can claim these deductions on their tax return for the 2025 tax year is forthcoming.

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



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IRS roundup: October 7 – October 23, 2025

by , , , and | Oct 28, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025.

October 7, 2025: The IRS issued Notice 2025-55, providing guidance on relief from failure to deposit penalties under Internal Revenue Code (Code) Section 6656 as it relates to a new excise tax being imposed on particular remittance transfers under Section 4475 for the first three quarters of 2026. The notice also includes guidance on the deposit safe harbor under Treas. Reg. § 40.6302(c)-1(b)(2), explaining that a remittance transfer provider will not be affected by failure to make deposits of the remittance transfer tax if they satisfy certain requirements.

October 16, 2025: The IRS issued Revenue Ruling 2025-21, providing various prescribed rates (for federal income tax purposes) for November 2025, including:

  • The short-, mid-, and long-term applicable federal rates (AFRs) for November 2025 as it relates to Section 1274(d).
  • The short-, mid-, and long-term adjusted AFRs for November 2025 as it relates to Section 1288(b).
  • The adjusted federal long-term rate and the long-term tax-exempt rate described in Section 382(f).

October 17, 2025: The IRS issued Revenue Procedure 2025-32, modifying certain sections of Revenue Procedure 2024-40 to reflect amendments resulting from the One Big Beautiful Bill Act (OBBBA). Revenue Procedure 2024-40, which displays IRS inflation-adjusted items for 2025, was specifically revised by removing the existing sections on standard deductions and the election to expense certain depreciable assets. Revenue Procedure 2025-32 also describes inflation-adjusted items for 2026 for various Code provisions.

October 21, 2025: The IRS issued Notice 2025-57, providing guidance on returns related to certain interest on specified passenger vehicle loans received in a trade or business from individuals, which are required to be filed under the new Section 6050AA as enacted in the OBBBA. Recognizing the need for efficient administration of Section 6050AA, Section 3 of Notice 2025-57 provides a means for interest recipients to report obligations under Section 6050AA.

October 22, 2025: The IRS issued frequently asked questions (FAQs) addressing Employee Retention Credits (ERC) under the ERC compliance provisions of the OBBBA. Although not final guidance, “a taxpayer who reasonably and in good faith relies on these FAQs will not be subject to a penalty that provides a reasonable cause standard for relief, including a negligence penalty or other accuracy-related penalty, to the extent that reliance results in an underpayment of tax.”

October 23, 2025: The IRS issued Notice 2025-63, announcing the US Department of the Treasury and IRS’s intentions to issue proposed regulations providing that certain borrow fees are sourced based on the recipient’s residence. Currently, neither the Code nor Treasury regulations specify how to determine borrow fees as they relate to securities lending transactions and sale-repurchase transactions. Thus, the Treasury and the IRS intend to clarify this in Notice 2025-63.

The IRS also released its weekly list of written determinations (e.g., Private [...]

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