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McDermott’s Real-Time Tax Disputes Insights
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McDermott’s Real-Time Tax Disputes Insights
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Weekly IRS Roundup January 8 – January 12, 2024

by , and | Jan 16, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 8, 2024 – January 12, 2024.

January 8, 2024: The IRS released Internal Revenue Bulletin 2024-2, which includes the following:

  • Notice 2024-7, which provides eligible taxpayers with automatic relief from additions to tax for failure to pay with respect to certain income tax returns for 2020 and 2021.
  • Announcement 2024-3, which explains Voluntary Disclosure Program eligibility criteria, terms and procedures for taxpayers to resolve refunds or credits for erroneous Employee Retention Credit (ERC) claims.
  • Notice 2024-2, which provides guidance on certain SECURE 2.0 Act of 2022 provisions.
  • Notice 2024-3, which sets forth the 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans.
  • Notice 2024-4, which updates the corporate bond monthly yield curve and corresponding spot segment rates for December 2023 used under Internal Revenue Code (Code) § 417(e)(3)(D), the 24-month average segment rates for December 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
  • Revenue Ruling 2024-1, which provides covered compensation tables under § 401(1)(5)(E) for the 2024 plan year.
  • Notice 2024-1, which provides the percentage increase for calculating the qualifying payment amounts for items and services furnished in 2024 for purposes of Code §§ 9816 and 9817, §§ 716 and 717 of the Employee Retirement Income Security Act of 1974, and §§ 2799A-1 and 2799A-2 of the Public Health Service Act.
  • Notice 2024-6, which provides additional guidance on the sustainable aviation fuel (SAF) credit, including methods and Renewable Fuel Standard program safe harbors used to qualify for and calculate the SAF credit.
  • Announcement 2024-1, 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).
  • Notice 2024-5, which provides a safe harbor for the incremental cost of certain qualified commercial clean vehicles placed in service in calendar year 2024 for purposes of the credit pursuant to § 45W.
  • Notice 2024-8, which provides the optional 2024 standard mileage rates that taxpayers can use when computing the deductible costs of operating an automobile for business, charitable, medical or moving expense purposes.
  • Notice 2024-9, which notes the IRS’s intent to propose regulations concerning statutorily required exceptions to the elective payment phaseout for entities that do not satisfy the domestic content requirements of §§ 45, 45Y, 48 and 48E. The notice also provides the transitional process for how applicable entities can claim the statutory exception for elective payment projects that begin construction during calendar year 2024 and fail to satisfy the domestic content requirement.
  • Notice 2024-11, which updates the list of treaties that meet the requirements of § 1(h)(11)(C)(i)(II) as it relates to [...]

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Weekly IRS Roundup November 13 – November 17, 2023

by | Nov 21, 2023 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023.

November 13, 2023: The IRS released Internal Revenue Bulletin 2023-46, which includes the following:

  • Proposed regulations that would update the requirements a plan sponsor of a single-employer defined benefit plan must meet to obtain IRS approval to use mortality tables specific to the plan when calculating the present value for minimum funding purposes (as a substitute for the generally applicable mortality tables). Comments and requests for a public hearing must be received by December 19, 2023.
  • Final regulations that prescribe mortality tables for certain defined benefit pension plans.
  • Announcement 2023-31, 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).

November 13, 2023: The IRS reminded taxpayers of the important steps they can take now to help them “get ready” to file their 2023 federal tax return for the 2024 filing season.

November 13, 2023: The IRS released FS-2023-26, updating question nine to reflect that wrongfully incarcerated US service members cannot exclude certain payments from gross income.

November 13, 2023: The IRS reminded people to stay vigilant in protecting personal and financial information from scam artists and tax schemes in light of International Fraud Awareness Week.

November 13, 2023: The IRS provided instructions for tax professionals to become an authorized e-file provider, which is mandatory for tax professionals to be able to file their clients’ federal tax returns electronically.

November 14, 2023: The IRS announced that it will hold a free webinar on November 16, 2023, to update employers, tax professionals and others on the most recent developments concerning e-file requirements for information returns that take effect on January 1, 2024.

November 14, 2023: The IRS released 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).

November 15, 2023: The IRS announced that Rajiv Uppal has been selected as the next Chief Information Officer.

November 15, 2023: The IRS announced that taxpayers can now claim tax credits for new and used clean vehicles they buy during the tax year, and starting January 1, 2024, they can transfer those tax credits to the dealer in exchange for a financial benefit.

November 15, 2023: The IRS released Revenue Ruling 2023-21, which provides various prescribed rates for federal income tax purposes for December 2023.

November 16, 2023: The IRS reminded individual retirement arrangement owners age 70½ or [...]

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Weekly IRS Roundup August 7 – August 11, 2023

by | Aug 14, 2023 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 7, 2023 – August 11, 2023.

August 7, 2023: The IRS published Internal Revenue Bulletin 2023-32, which includes:

  • Notice 2023-53, setting forth updates on the corporate bond monthly yield curve and the corresponding spot segment rates for July 2023 used under Code Section 417(e)(3)(D); the 24-month average segment rates applicable for July 2023; and the 30-year Treasury rates, as reflected by the application of Code Section 430(h)(2)(C)(iv).
  • Proposed regulations that would rescind the moral objection exemption to providing contraceptive services in health plans subject to the Patient Protection and Affordable Care Act and establish a new individual contraceptive arrangement that individuals enrolled in plans or coverage sponsored, arranged, or provided by objecting entities may use to obtain contraceptive services at no cost directly from a provider or facility that furnishes contraceptive services.
  • Final regulations that authorize the assessment and collection of erroneous refunds of various credits in the normal course of processing employment tax returns.
  • Announcement 2023-22, revoking tax-exempt status for certain organizations.
  • Notice 2023-55, providing temporary relief in defining a “foreign income tax” for purposes of Code Sections 901 and 903 for 2022 and 2023 tax years.
  • Revenue Ruling 2023-13, listing the applicable federal rates for August 2023.

August 7, 2023: The IRS reminded eligible contractors who build or substantially reconstruct qualified new energy-efficient homes that they might qualify for a tax credit of up to $5,000 per home under Code Section 45L. The credit amount depends on the type of home, the home’s energy efficiency and the date when someone buys or leases the home.

August 8, 2023: The IRS released part four of a five-part “Protect Your Client; Protect Yourself” summer series from the Security Summit, a public-private partnership that works to protect the tax system against tax-related identity theft and fraud. This publication provides information to help protect sensitive taxpayer data.

August 8, 2023: The IRS released Tax Tip 2023-99, explaining the various ways in which scammers may impersonate the IRS, including by mail, electronically and even in person.

August 8, 2023: The IRS’s Large Business and International Division announced a compliance campaign focused on taxpayers who may have inflated their reported cost of goods sold to reduce their taxable income.

August 9, 2023: The IRS warned businesses and tax professionals to be aware of a range of compliance issues associated with employee stock ownership plans (ESOPs). The IRS indicated that it is aware of promoted arrangements using ESOPs that are potentially abusive. Such arrangements may include schemes where a business creates a “management” S corporation whose stock is wholly owned by an ESOP for the sole purpose of diverting taxable business income to the ESOP. The S [...]

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Weekly IRS Roundup July 24 – July 28, 2023

by | Aug 1, 2023 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023.

July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30, which includes proposed regulations that specify the methodology for constructing the corporate bond yield curve used to calculate present value under a defined benefit plan. The Internal Revenue Bulletin also highlights the following:

  • Announcement 2023-18 relieves taxpayers from reporting the new stock repurchase excise tax under § 4501.
  • Announcements 2023-19 and 2023-20 revoke the tax-exempt status of certain organizations.
  • Notice 2023-37 modifies prior guidance regarding benefits related to testing and treating COVID-19.
  • Notice 2023-50 announces that the applicable percentage for purposes of determining percentage depletion on marginal properties for 2023 is 15%.
  • Notice 2023-51 publishes the inflation adjustment factor and the reference price for 2023 for the renewable electricity production credit under § 45.
  • T.D. 9976 provides final regulations that facilitate the transition from the London Interbank Offered Rate (LIBOR) to other interbank offered rates (IBORs).

July 24, 2023: The IRS released Tax Tip 2023-93, warning businesses and tax-exempt organizations about misleading employee retention credit claims. Scammers and unscrupulous promoters have been running aggressive broadcast advertising, direct mail solicitations and online promotions for the credit, many of which misrepresent and exaggerate who can qualify for the credit.

July 24, 2023: The IRS announced that revenue officers will no longer make unannounced visits to taxpayers’ residences in all but a few narrow circumstances. Instead, they will schedule visits via mailed letters.

July 25, 2023: The IRS released Tax Tip 2023-94, advising that applicable entities, including tax-exempt and governmental entities that would otherwise be unable to claim certain credits because they do not owe federal income tax, can benefit from some clean energy tax credits. If an entity opts to receive an elective payment, the amount of such credits is treated as a payment of tax, and overpayments will result in a refund.

July 25, 2023: The IRS released Notice 2023-53, which provides guidance on the corporate bond monthly yield curve, spot segment rates used under § 417(e)(3) and the 12-month average segment rates under § 430(h)(2).

July 25, 2023: The IRS published a special summer series discussing the Identity Protection PIN Opt-In Program, which can provide an extra layer of security for taxpayers filing their tax returns.

July 26, 2023: The IRS released Tax Tip 2023-95, reminding taxpayers that IRS Free File remains available until October 16 for those who still need to file a 2022 tax return.

July 26, 2023: The IRS released Revenue Procedure 2023-26, which provides a program for the fast-track processing of private letter ruling requests, replacing the pilot program described in
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Weekly IRS Roundup November 14 – November 18, 2022

by | Nov 21, 2022 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 14, 2022 – November 18, 2022.

November 14, 2022: The IRS released Internal Revenue Bulletin 2022-46, which highlights the following:

  • Announcement 2022-21: The Office of Professional Responsibility announced recent disciplinary sanctions involving lawyers, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents and appraisers.

November 14, 2022: The IRS released Notice 2022-59, which provides the adjusted applicable dollar amount to be multiplied by the average number of covered lives for purposes of calculating the fee imposed by Sections 4375 and 4376 for policy years and plan years that end on or after October 1, 2022, and before October 1, 2023. The amount is $3.00, up from $2.79.

November 14, 2022: The IRS released Tax Tip 2022-174, which provides an overview of the Taxpayer Bill of Rights (TBOR). We have previously posted about TBOR.

November 15, 2022: The IRS released Tax Tip 2022-175, reminding people that Giving Tuesday is coming up and is a good time to review whether their charitable donation is tax deductible. Giving Tuesday is the Tuesday after Thanksgiving.

November 15, 2022: The IRS reminded taxpayers that IRS Free File will be closed after November 17. IRS Free File allows people with incomes of $73,000 or less to file a return online for free using brand name software.

November 15, 2022: The IRS Advisory Council issued its 2022 Public Report, which includes recommendations for new and continuing issues in tax administration. The report emphasized the need for “consistent and multi-year funding for the IRS to achieve its goals of providing efficient, effective, modern service to the nation’s taxpayers.” The 146-page report details recommendations for 21 issues, including:

  • IRS business and information technology modernization
  • Reduction in electronic filing threshold for information return filers
  • Alignment of electronic signature requirements on withholding certificates
  • Accelerated issuance of IRS Form 6166, Certification of US Residency
  • Series 8038 Form Redesign and Updates
  • Business Master File Transcript Delivery Service

November 15, 2022: The IRS issued Revenue Rule 2022-22, which provides the applicable federal rates for federal income tax purposes for December 2022. The short-term federal interest rate will increase to 4.55%, the mid-term rate will rise to 4.27% and the long-term rate will rise to 4.34%.

November 16, 2022: The IRS released Revenue Procedure 2022-39, which obsoletes Revenue Procedure 94-69, 1994-2 C.B. 804, and sets out the procedures for eligible taxpayers to file an amended return in accordance with Section 1.6664-2(c)(4)(ii) of the regulations. This revenue procedure also sets out the procedures for eligible taxpayers to avoid the Sections 6662(b)(1) and 6662(b)(2) accuracy related penalties to the extent that the taxpayers report errors resulting in additional tax or adequately discloses the tax treatment of an [...]

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