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IRS roundup: January 21 – February 9, 2026

by Suzanne Golshanara, Edward L. Froelich and Matthew J. Blaney | Feb 11, 2026 | Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 21, 2026 – February 9, 2026.

January 26, 2026: The IRS released Notice 2026-9, which provides a one-year extension to make certain amendments to individual retirement arrangements (IRAs), simplified employee pension arrangements, and savings incentive match plan for employees IRA plans. The new deadline is December 31, 2027. The extension gives the IRS additional time to issue model language for the various changes resulting from compliance with the SECURE 2.0 Act of 2022 and related legislation.

January 27, 2026: The IRS released Fact Sheet 2026-2, which provides updated questions and answers regarding the implementation of Executive Order 14247, Modernizing Payments To and From America’s Bank Account. The executive order advances the transition to fully electronic federal payments both to and from IRS.

January 29, 2026: The IRS announced that it is accepting applications for the Electronic Tax Administration Advisory Committee (ETAAC) through February 28, 2026. The ETAAC provides an organized public forum for discussing electronic tax administration issues, such as prevention of identity theft and refund fraud.

February 2, 2026: The IRS released Internal Revenue Bulletin No. 2026-6, which includes Announcement 2026-3. The announcement provides a copy of the arrangement entered into by the competent authorities of the United States and Spain regarding the implementation of the arbitration process provided for in paragraphs 5 and 6 of Article 26 of the US-Spain income tax treaty and its protocol.

February 2, 2026: The IRS announced that it would continue operations under the current lapse in appropriations until further notice, using funding from the Inflation Reduction Act of 2022 (IRA).

February 3, 2026: The US Department of the Treasury and the IRS issued proposed regulations regarding the clean fuel production credit enacted by the IRA and amended by the One Big Beautiful Bill Act. The new law made important changes to what is often referred to as the 45Z credit. The proposed regulations would provide rules for determining clean fuel production credits. They also would amend three sets of final regulations: the elective payment election regulations and the credit transfer election regulations (to clarify language relating to ownership of clean fuel production facilities) and the federal excise tax registration regulations (to make them clearer and more consistent with the clean fuel production credit registration requirements in these proposed regulations). The proposed regulations would affect domestic producers of clean transportation fuel, taxpayers that may claim a credit for a related producer’s fuel, and excise tax registrants. Comments must be received by April 6, 2026. There is a public hearing that will be held on May 28, 2026, and requests to speak at the public hearing will be accepted until May 26, 2026.

Recent court decisions

January 28, 2026: The US Tax Court issued its opinion in Aventis Inc. v. Commissioner, rejecting Aventis’s attempt to treat [...]

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Weekly IRS Roundup October 9 – October 13, 2023

by Evan Walters | Oct 19, 2023 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 9, 2023 – October 13, 2023.

October 10, 2023: The IRS released Internal Revenue Bulletin 2023-41, which includes the following:

Revenue Ruling 2023-19 sets forth updated terminal charge and Standard Industry Fare Level formula mileage rates for valuing noncommercial flights on employer-provided aircrafts for purposes of taxing fringe benefits under Treasury Regulation § 1.61-21(g).
Notice 2023-68 provides the special per diem rates for purposes of substantiating ordinary and necessary business expenses relating to (1) meal and incidental expenses within the transportation industry, (2) incidental expenses only and (3) allowances under the high-low substantiation method.
Revenue Procedure 2023-32 publishes the amount of unused housing credit carryovers allocated to qualified states under Code Section 42(h)(3)(D) for calendar year 2023.
Announcement 2023-29 revokes tax-exempt status from certain organizations.

October 10, 2023: The IRS reminded taxpayers filing on extension to gather all records and copies of missing documents before they prepare their returns on their own or visit a tax preparer.

October 12, 2023: The IRS released new tax gap projections for tax years 2020 and 2021. The projections estimate an increase in the gross tax gap to $688 billion in tax year 2021, which reflects a rise of more than $192 billion from prior estimates for tax years 2014 through 2016 and a rise of $138 billion from the revised projections for tax years 2017 through 2019.

October 13, 2023: The IRS released Notice 2023-71, extending all tax filing and payment deadlines from October 7, 2023, until October 7, 2024, for taxpayers affected by the recent terrorist attacks in Israel. The relief applies to:

Any individual whose principal residence or business entity is located in Israel, the West Bank or Gaza
Any sole proprietor whose principal place of business is located in Israel, the West Bank or Gaza
Any individual, business, sole proprietor, estate or trust whose books, records or tax preparer is located in Israel, the West Bank or Gaza
Any individual who was killed, injured or taken hostage during the terrorist attacks
Any individual affiliated with a recognized government or philanthropic organization and is assisting in Israel, the West Bank or Gaza (such as a relief worker)

October 13, 2023: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Statutes of Limitation in the International Tax Context

by Elizabeth Chao and Lowell D. Yoder | Oct 19, 2017 | IRS Audits, IRS Guidance, Trial Courts, Uncategorized

As most taxpayers know, under Internal Revenue Code (Code) Section 6501(a), the Internal Revenue Service (IRS) generally has three years after a tax return is filed to assess any additional tax. However, Code Section 6501 provides several exceptions to this rule, including but not limited to the following.

False or fraudulent returns with the intent to evade tax (unlimited assessment period)
Willful attempt to defeat or evade tax (unlimited assessment period)
Failure to file a return (unlimited assessment period)
Extension by agreement (open-ended or for a specific period)
Adjustments for certain income and estate tax credits (separately provided in specific statutes)
Termination of private foundation status (unlimited assessment period)
Valuation of gifts of property (unlimited assessment period)
Listed transactions (assessment period remains open for one year after certain information is furnished)
Substantial omission of items (six-year assessment period)
Failure to include certain information on a personal holding company return (six-year assessment period)

If the IRS issues a notice of deficiency and the taxpayer files a petition in the Tax Court, the statute of limitations on assessment is extended until after the Tax Court’s decision becomes final. See Code Section 6503(a); see also Roberson and Spencer, “11th Circuit Allows Invalid Notice to Suspend Assessment Period,” 136 Tax Notes 709 (August 6, 2012). (more…)