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Weekly IRS Roundup January 15 – January 19, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024.

January 16, 2024: The IRS released Internal Revenue Bulletin 2024-3, which includes the following:

  • Notice 2024-10, which provides guidance on the corporate alternative minimum tax, including rules for determining the “adjusted financial statement income” of a US shareholder when a controlled foreign corporation pays a dividend and modifications to Notice 2023-64.
  • Proposed regulations, which provide guidance on the new Internal Revenue Code (Code) Section 45X advanced manufacturing production credit established by the Inflation Reduction Act of 2022 (IRA). This credit is intended to incentivize domestic production of certain green energy components.
  • Final regulations regarding penalty protections for de minimis errors on information returns and payee statements.

January 16, 2024: The IRS released transitional guidance under Code Section 60501 on reporting transactions involving the receipt of digital assets and clarified that at this time, digital assets are not required to be included when determining whether cash received in a single transaction (or two or more related transactions) meets the reporting threshold.

January 16, 2024: The IRS issued Revenue Ruling 2024-3, which provides the February 2024 applicable federal rates.

January 16, 2024: The IRS reminded taxpayers of their rights under the Taxpayer Bill of Rights, which includes 10 rights all taxpayers have any time they interact with the IRS. Those rights include privacy, confidentiality and the right to appeal an IRS decision in an independent forum.

January 17, 2024: The IRS announced the appointment of 12 new members to the Internal Revenue Service Advisory Council, a public forum that provides the IRS and agency leaders with feedback, observations and recommendations related to tax administration.

January 18, 2024: The IRS reached a major milestone in the implementation of key provisions in the IRA as more than 1,000 projects have now been registered through the new IRS Energy Credits Online tool.

January 18, 2024: The IRS alerted a limited group of tax-exempt organizations subject to unrelated business income tax that they will not be able to electronically file Form 990-T, Exempt Organization Business Income Tax Return, or Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations, until March 17, 2024.

January 19, 2024: The IRS issued Notice 2024-20, which provides guidance on the qualified alternative fuel vehicle refueling property credit under Code Section 30C. The IRS intends to issue additional guidance via proposed regulations.

January 19, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).




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Weekly IRS Roundup December 11 – December 15, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 11, 2023 – December 15, 2023.

December 11, 2023: The IRS released Internal Revenue Bulletin 2023-50, which includes the following:

  • Proposed regulations that would update regulations under Internal Revenue Code (Code) §§ 267 and 707 to apply an entity approach to partnerships for purposes of applying loss limitation rules to related persons. The proposed regulations are intended to conform the existing regulations to current law. Comments and requests for a public hearing must be received by February 26, 2024.
  • Proposed regulations that relate to the calculation of foreign currency gains and losses under Code § 987. The proposed regulations include a current rate election, which would treat all balance sheet items as marked items and would require that income, gain, loss and deduction with respect to a qualified business unit be translated at a yearly average exchange rate. The proposed regulations also include an annual recognition election, which would trigger all items of income, gain, loss and deduction on an annual basis. Comments and requests for a public hearing must be received by February 12, 2024.

December 11, 2023: The IRS issued Notice 2023-80, which announces the intention to issue proposed regulations that address the application of the foreign tax credit (FTC) and dual consolidated losses in relation to the Global Anti-Base Erosion (GloBE) Model Rules. The notice also (i) extends the temporary relief period described in Notice 2023-55 for determining whether a foreign tax is eligible for an FTC pursuant to §§ 901 and 903 and (ii) addresses application of the temporary relief with respect to partnerships and their partners.

December 11, 2023: The IRS urged taxpayers to take certain important actions to help them file their 2023 federal income tax return for the upcoming filing season, including (i) making quarterly payments by January 16, 2024, if required, (ii) gathering 2023 tax documents, (iii) considering whether to file electronically and choosing direct deposit to expedite tax refunds, and (iv) reviewing energy-related credits. The IRS also reminded taxpayers that they can now view their IRS account transcripts online and should not rely on receiving refunds by a certain date.

December 13, 2023: The IRS announced plans for a new leadership structure at the agency that will feature a single deputy IRS Commissioner and four new IRS chief executive positions to cover taxpayer service, compliance, information technology and operations.

December 13, 2023: The IRS published Tax Tip 2023-126, which states that business taxpayers can electronically file any Form 1099 series information returns for free with the IRS Information Returns Intake System.

December 14, 2023: The US Department of the Treasury and the IRS issued proposed regulations on the § 45X advanced manufacturing production credit. The proposed [...]

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