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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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Weekly IRS Roundup December 4 – December 8, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 4, 2023 – December 8, 2023.

December 4, 2023: The IRS released Internal Revenue Bulletin 2023-49, which includes the following:

  • Revenue Ruling 2023-22, which establishes certain interest rates pursuant to § 6621 of the Internal Revenue Code (Code) for the calendar quarter beginning January 1, 2024.
  • Notice 2023-76, which updates the corporate bond monthly yield curve and corresponding spot segment rates for November 2023 used under § 417(e)(3)(D), the 24-month average segment rates for November 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
  • Proposed regulations regarding excise taxes on taxable distributions made by a sponsoring organization from a donor advised fund. Comments and requests for a public hearing must be received by January 16, 2024.
  • Announcement 2023-34, which revokes § 501(c)(3) determinations for certain organizations and stipulates that contributions made to the organizations by individual donors are no longer deductible under § 170(b)(1)(A).
  • Proposed regulations that provide guidance on the statutory disallowance of qualified conservation contributions made by partnerships and S corporations if the amount of the charitable contribution exceeds 2.5 times the sum of each partner’s or S corporation shareholder’s relevant basis. Comments must be received by December 20, 2023.
  • A Notice of Proposed Rulemaking that reopens the comment period for proposed regulations relating to the determination and recognition of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit pursuant to § 987. Comments and requests for a public hearing must be received by February 12, 2024.
  • Revenue Ruling 2023-21, which provides the applicable federal rates for December 2023.

December 6, 2023: The IRS announced that it sent more than 20,000 letters to taxpayers disallowing Employee Retention Credit (ERC) claims. These letters are part of the ongoing IRS initiative against dubious ERC claims involving entities that did not exist or did not pay wages during the eligibility period.

December 7, 2023: The IRS requested applications for nomination to the Electronic Tax Administration Advisory Committee through January 31, 2024.

December 7, 2023: The IRS released Revenue Procedure 2023-41, which prescribes discount factors for the 2023 accident year for use by insurance companies in computing discounted unpaid losses pursuant to § 846 and discounted estimated salvage recoverable pursuant to § 832.

December 8, 2023: The IRS released Notice 2023-79, which sets forth the 2023 Required Amendments List that applies to § 401(a) and § 403(b) individually designated plans.

December 8, 2023: The IRS released Revenue Procedure 2024-8, which provides a list of qualified census tracts for each state, the District of Columbia and Puerto Rico for issuers of qualified mortgage bonds [...]

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Weekly IRS Roundup November 6 – November 10, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023.

November 6, 2023: The IRS released Internal Revenue Bulletin 2023-45, which includes the following:

  • Final regulations that increase the user fees for new and renewal enrollment of enrolled actuaries to $680, up from $250.
  • Notice 2023-70 provides that $3.22 is the adjusted applicable dollar amount for determining the Patient-Centered Outcomes Research Trust Fund fee for policy years and plan years ending on or after October 1, 2023, and before October 1, 2024.
  • Notice 2023-72 updates the corporate bond monthly yield curve and the corresponding spot segment rates for October 2023 used under § 417(e)(3)(D), the 24-month average segment rates for October 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
  • Notice 2023-73 specifies a mortality table for determining the minimum present value under § 417(e)(3) of the Internal Revenue Code and Section 205(g)(3) of the Employee Retirement Income Security Act of 1974 for distributions with annuity starting dates that occur during stability periods beginning in the 2024 calendar year.
  • Announcement 2023-30 revokes § 501(c)(3) determination(s) for certain organization(s) and stipulates that contributions made to the organization(s) by individual donors are no longer deductible under § 170(b)(1)(A).
  • Revenue Ruling 2023-20 provides the November 2023 applicable federal rates.

November 6, 2023: The IRS published Tax Tip 2023-120, which notes that volunteers are needed to fill a variety of roles in two IRS volunteer programs.

November 7, 2023: The IRS released FS-2023-25, announcing that taxpayers are now able to digitally submit all correspondence and responses to notices. New updates to the “Where’s My Refund?” tool will launch during the 2024 filing season.

November 7, 2023: The IRS announced that the telephonic-only public hearing on digital asset transactions has been rescheduled for November 13, 2023.

November 8, 2023: The IRS reminded dealers and sellers of clean vehicles to register their organizations immediately via the Energy Credits Online tool. The IRS urges registration by December 1, 2023, to ensure benefits are available by January 1, 2024.

November 9, 2023: The IRS Advisory Council issued its annual report for 2023, which includes recommendations for the IRS regarding new and continuing issues in tax administration.

November 9, 2023: The IRS announced the annual inflation adjustments for more than 60 tax provisions for tax year 2024, including the tax rate schedules and other tax changes. Further annual adjustment details may be found in Revenue Procedure 2023-34.

November 9, 2023: The IRS issued its fiscal year 2023 Financial Report.

November 9, 2023: The IRS published Tax [...]

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