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Weekly IRS Roundup September 18 – September 22, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 18, 2023 – September 22, 2023.

September 18, 2023: The IRS released Internal Revenue Bulletin 2023-38, which includes the following:

September 18, 2023: The IRS published Tax Tip 2023-111, describing different types of third-party representatives.

September 19, 2023: The IRS published Tax Tip 2023-112, describing how taxpayers can be certain they are communicating with the IRS as opposed to scammers purporting to represent the IRS.

September 19, 2023: The IRS reminded individuals and businesses in parts of Alabama, California and Georgia that their 2022 federal income tax returns and tax payments are due October 16, 2023. The original due date for these returns was postponed because of natural disasters.

September 19, 2023: The IRS has selected eight new members for the Electronic Tax Administration Advisory Committee (ETAAC), which is a public forum for the discussion of electronic tax administration issues. ETAAC members work closely with the Security Summit, a joint effort of the IRS, state tax administrators and the nation’s tax industry to fight identity theft and refund fraud.

September 20, 2023: The IRS published Tax Tip 2023-113, discussing the expanded tax credit for contractors who build energy-efficient homes.

September 20, 2023: The IRS announced plans to establish a special area that will focus on large or complex pass-through entities. The new work unit will be housed in the IRS Large Business and International (LB&I) division.

September 22, 2023: The IRS is requesting comments on Revenue Procedure 2004-47, which permits taxpayers who failed to make a reverse qualified terminable interest property (QTIP) election on an estate tax return to file certain documents with the Cincinnati Service Center directly to request relief in lieu of requesting a private letter ruling. Comments are invited on:

  • Whether the collection of information is necessary for the proper performance of the agency’s functions, including whether the information has practical utility
  • The accuracy of the agency’s estimate for the burden of the information collection
  • Ways to enhance the quality, utility and clarity of the information to be collected
  • Ways to minimize the burden of the information collection on other forms of information technology
  • Estimates for capital or startup costs and costs of operation, maintenance and purchase of services to provide information.

September 22, 2023: The IRS released its weekly list of written [...]

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Weekly IRS Roundup July 17 – July 21, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 17, 2023 – July 21, 2023.

July 17, 2023: The IRS released Internal Revenue Bulletin 2023-29, which includes Notices 2023-29, 2023-45 and 2023-47. These notices provide guidance to taxpayers seeking to qualify for the energy community bonus credit under §§ 45, 45Y, 48 and 48E.

July 17, 2023: The IRS released Revenue Ruling 2023-13, providing the applicable federal rates for federal income tax purposes for August 2023. The short-term federal interest rate is 5.07%, the mid-term rate is 4.09% and the long-term rate is 4.03%.

July 17, 2023: The IRS released Tax Tip 2023-90, identifying summer activities that can affect individuals’ tax returns. For example, the cost of sending a child to summer camp may count toward the Child and Dependent Care Credit.

July 19, 2023: The IRS released Tax Tip 2023-91, reminding newlywed couples to report any name or address changes to the Social Security Administration, the US Postal Service and the IRS to update their withholding allowances. The Tax Tip also clarifies that a couple married as of December 31 is treated as married for the whole year for tax purposes.

July 20, 2023: The IRS released Tax Tip 2023-92, providing guidance to taxpayers filing returns on extension and reminding them that they may be eligible to use IRS Free File. Taxpayers getting a refund can expect to receive it faster by requesting that the refund be paid electronically via direct deposit.

July 21, 2023: The IRS released Notice 2023-55, which provides relief for taxpayers in determining which foreign taxes are creditable for tax years beginning on or after December 28, 2021, and ending on or before December 31, 2023.

July 21, 2023: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Upcoming Events: Registration for the 2023 IRS Nationwide Tax Forums is now open, and the events are returning to an in-person format for the first time since 2019. The IRS Nationwide Tax Forums are designed specifically for tax professionals (e.g., enrolled agents, certified public accountants, certified financial planners and Annual Filing Season Program participants) as well as uncredentialed tax professionals. The dates and locations are as follows:

  • July 25-27: Atlanta, GA
  • August 8-10: National Harbor, MD (Washington, DC area)
  • August 22-24: San Diego, CA
  • August 29-31: Orlando, FL



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Weekly IRS Roundup June 5 – June 9, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023.

June 5, 2023: The IRS released Internal Revenue Bulletin 2023-23, which highlights the following:

  • Revenue Ruling 2023-11: This revenue ruling establishes that the following interest rates will remain the same for the calendar quarter beginning July 1, 2023:
    • Overpayments: 7%
    • Overpayments for corporations: 6%
    • Corporate overpayments for portions exceeding $10,000: 4.5%
    • Underpayments: 7%
    • Large corporate underpayments: 9%
  • Notice 2023-41: This notice provides the applicable reference price for qualified natural gas production from qualified marginal wells during taxable years beginning in calendar year 2022 for the purpose of determining the marginal well production credit under Section 45I.
  • REG-108054-21: These proposed regulations provide guidance on the application of the transfer for valuable consideration rules under Section 101 and associated information reporting requirements for reportable policy sales of interests in life insurance contracts under Section 6050Y. The proposed regulations would amend the rules for exchanges of life insurance contracts qualifying for nonrecognition of gain or loss, as well as for certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations.
  • Revenue Ruling 2023-10: This revenue ruling provides the applicable federal rates for federal income tax purposes for June 2023. The short-term federal interest rate is 4.43%, the mid-term rate will drop to 3.56% and the long-term rate is 3.79%.

June 6, 2023: The IRS released Tax Tip 2023-76, providing business taxpayers with tips for income tax deductions before they travel on work trips.

June 7, 2023: The IRS issued a statement reassuring California taxpayers covered by disaster declarations that they’ll continue to have an automatic extension to file and pay taxes. The IRS is legally required to send a Notice CP14 to taxpayers with a balance due. While the notice says they need to pay in 21 days, California taxpayers under the disaster declaration have until later this year to pay.

June 7, 2023: The IRS released Tax Tip 2023-77, reminding tax professionals to register for the 2023 IRS Nationwide Tax Forums. Early registration expires June 15. See additional information below under Upcoming Events.

June 7, 2023: The IRS announced it was granting penalty relief for corporations that did not pay estimated tax related to the new corporate alternative minimum tax (CAMT). Notice 2023-42 provides that the IRS will waive the penalty for failure to pay estimated income tax for a taxable year that begins after December 31, 2022, and before January 1, 2024, because of the challenges associated with determining the amount of a corporation’s CAMT liability and whether a corporation is subject to the CAMT.

June 7, 2023: The IRS reminded taxpayers of the 2023 mid-June [...]

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Weekly IRS Roundup May 8 – May 12, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 – May 12, 2023.

May 8, 2023: The IRS released Internal Revenue Bulletin 2023-19, which highlights the following:

  • Revenue Procedure 2023-22: This revenue procedure provides qualified mortgage bond issuers and mortgage credit certificate issuers with (1) the nationwide average purchase price for residences located in the United States, and (2) the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands and Guam.
  • Announcement 2023-14: This announcement provides the revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).
  • Notice 2023-34: This notice provides that convertible virtual currency should be treated as property for federal tax purposes and general tax principles applicable to property transactions apply to transactions using convertible virtual currency. This notice modifies Notice 2014-21 by revising a sentence in the background section to remove the statement that virtual currency does not have legal tender status in any jurisdiction, among other changes.
  • Revenue Procedure 2023-21: This revenue procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Section 842(b) for taxable years beginning after December 31, 2021.
  • Revenue Ruling 2023-9: This revenue ruling provides the applicable federal rates for federal income tax purposes for May 2023. The short-term federal interest rate is 4.30%, the mid-term rate will drop to 3.57% and the long-term rate will fall to 3.72%

May 8, 2023: The IRS announced Saturday hours for May 13 in more than 40 locations across 25 states. The Saturday hours were to help taxpayers who may have a tax concern or questions about an IRS notice.

May 8, 2023: The IRS released Tax Tip 2023-63, providing IRS websites and other publications with tax-related disaster relief information that can help taxpayers.

May 9, 2023: The IRS announced that it will accept applications for Low Income Taxpayer Clinic (LITC) matching grants from May 8, 2023, to June 26, 2023. The funding will be for the 2023 calendar year. The IRS awards matching grants to qualifying organizations to develop, expand or maintain an LITC. An LITC must match every dollar of funding awarded by the IRS.

May 9, 2023: The IRS released Tax Tip 2023-64, highlighting the Taxpayer Bill of Rights and the right to challenge the IRS’s position.

May 10, 2023: The IRS released Notice 2023-39, which describes proposed amendments to [...]

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Weekly IRS Roundup April 17 – April 21, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023.

April 17, 2023: The IRS released Internal Revenue Bulletin 2023-16, which highlights the following:

  • Announcement 2023-10: This announcement was issued pursuant to the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the US Secretary of the Treasury to annually report advance pricing agreements and the Advance Pricing and Mutual Agreement Program (APMA Program). This year’s report describes the experience, structure and activities of the APMA Program during 2022.
  • REG-105954-22: This notice provides guidance related to Sections 4661, 4662, 4671 and 4672, collectively referred to as the Superfund chemical taxes. Section 4661(a) imposes an excise tax on the sale or use of “taxable chemicals” by manufacturers, producers or importers. Section 4671(a) imposes an excise tax on the sale or use of “taxable substances” by importers. The Superfund chemical taxes previously expired on December 31, 1995, but were reinstated with certain modifications, effective July 1, 2022, by Section 80201 of the Infrastructure Investment and Jobs Act.
  • Notice 2023-31: This notice announces that when proposed regulations under Section 903 (REG-112096-22) are finalized, the US Department of the Treasury and the IRS intend to extend the transition period for the single-country exception’s documentation requirement from May 17, 2023, to 180 days after the final regulations are filed. The single-country exception provides relief from the source-based attribution requirement under Section 903 for foreign withholding taxes on royalties paid for the use of intellectual property within the withholding jurisdiction.
  • REG-120080-22: This document contains proposed regulations regarding the clean vehicles credit under Section 30D. These proposed regulations will affect persons seeking to claim the credit and qualified manufacturers of clean vehicles. The IRS also issued a reminder that the proposed regulations went into effect on April 18.
  • Revenue Ruling 2023-2: This revenue ruling confirms that the basis adjustment under Section 1014 generally does not apply to the assets of an irrevocable grantor trust not included in the deceased grantor’s gross estate for federal estate tax purposes.

April 17, 2023: The IRS released Revenue Ruling 2023-9, which provides the applicable federal rates for federal income tax purposes for May 2023. The short-term federal interest rate is 4.30%, the mid-term rate will drop to 3.57% and the long-term rate will fall to 3.72%.

April 17, 2023: The IRS reminded taxpayers who need additional time to file their taxes that they can get an extension via IRS Free File.

April 17, 2023: The IRS released Tax Tip 2023-51, providing information to taxpayers regarding how to file a final federal tax return for someone who has died.

April 17, 2023: The IRS reminded last-minute tax [...]

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Weekly IRS Roundup April 3 – April 7, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 3, 2023 – April 7, 2023.

April 3, 2023: The IRS released Internal Revenue Bulletin 2023-14, which highlights the following:

  • Notice 2023-25: This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates and the 24-month average segment rates. It also provides guidance as to the interest rate on 30-year Treasury securities as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate.
  • Revenue Ruling 23-6: This revenue ruling provides the applicable federal rates for federal income tax purposes for April 2023. The annual short-term rate is 3.67%, the mid-term rate is 3.14% and the long-term rate is 3.04%.

April 3, 2023: The IRS released Notice 2023-31, announcing an Extension of the Transition Period for the Single-Country Exception Under Section 903.

April 3, 2023: The IRS announced special Saturday hours at Taxpayer Assistance Centers. The final Saturday opening will be May 13, 2023, from 9:00 am to 4:00 pm.

April 3, 2023: The IRS released the last entry in its Dirty Dozen campaign, cautioning taxpayers to beware of promoters peddling bogus tax schemes aimed at reducing or avoiding taxes.

April 3, 2023: The IRS announced that Arkansas storm victims now have until July 31, 2023, to file various federal individual and business tax returns and make tax payments as a result of storms that occurred on March 31, 2023. Relief is available to anyone in an area designated by the Federal Emergency Management Agency as qualifying for individual or public assistance. The current list of eligible localities is available here.

April 3, 2023: The IRS reminded taxpayers that tax credits are available for a portion of the qualifying expenses related to energy improvements to their homes. Taxpayers can claim either the Energy Efficient Home Improvement Credit or the Residential Energy Clean Property Credit for the year when qualifying improvements are made.

April 3, 2023: The IRS released Tax Tip 2023-43, reminding taxpayers that IRS.gov has tax information in seven languages: Spanish, Chinese Traditional, Chinese Simplified, Korean, Russian, Vietnamese and Haitian Creole.

April 4, 2023: The IRS released Revenue Procedure 2023-12, which updates the procedures for exempt organizations determination letters with respect to the electronically submitted Form 8940, Request for Miscellaneous Determination. This modification to Revenue Procedure 2023-5 provides that the electronic submission process is the exclusive means of submitting a completed Form 8940, except for submissions eligible for the 90-day transition relief.

April 4, 2023: The IRS announced guidance related to the eligibility requirement for energy communities for the bonus credit program under the Inflation Reduction Act of 2022 (IRA). Notice 2023-29 describes certain [...]

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Weekly IRS Roundup March 13 – March 17, 2023

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

March 13, 2023: The IRS released Internal Revenue Bulletin 2023-11, which highlights the following:

  • Notice 2023-21: This notice postpones the beginning of the lookback periods under Section 6511 for certain taxpayers to file a claim for refund. Affected taxpayers include those who had tax returns due from April 15, 2020 to July 15, 2020, or from April 15, 2021 to May 17, 2021, and due to the COVID-19 pandemic, those due dates were postponed by Notice 2020-23 or Notice 2021-21 to July 15, 2020 or May 17, 2021, respectively.
  • Treasury Decision 9972: These final regulations amend the rules for filing certain returns and statements electronically to reflect changes made by the Taxpayer First Act of 2019 and to promote electronic filing.
  • Notice 2023-19: This notice provides guidance on the corporate bond monthly yield curve, corresponding spot segment rates and the 24-month average segment rates for February 2023. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.
  • REG 122286-18: These proposed regulations provide rules relating to the use of forfeitures in qualified retirement plans, including a deadline for the use of forfeitures in defined contribution plans, and clarify that forfeitures arising in any defined contribution plan may be used for one or more of the following purposes, as specified in the plan, to (1) pay plan administrative expenses, (2) reduce employer contributions under the plan or (3) increase benefits in other participants’ accounts in accordance with plan terms.
  • Action on Decision 2023-2: The IRS announced nonacquiescence to the US Tax Court’s decision in Complex Media, Inc. v. Commissioner, T.C. Memo. 2021-14, that the parties’ failure to report transactions fully or consistently should not be a major factor in a decision of whether to allow a taxpayer to disavow the form of its transactions and to the standard the Court applied to allow a petitioner to disavow its form. The IRS also announced nonacquiescence to the court’s determination that the fair market value of a “Deferred Payment Right” for purposes of Section 351(b)(1) is not equal to its issue price.
  • Treasury Decision 9973: This document contains final regulations that treat members of a consolidated group as a single US shareholder in certain cases for purposes of Section 951(a)(2)(B). The final regulations affect consolidated groups that own stock of foreign corporations.

March 13, 2023: The IRS announced that Danny Werfel began work as the 50th Commissioner of the IRS. Werfel was confirmed by the US Senate on March 9, 2023, and his term will run through November 12, 2027. You can read more about his confirmation
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Weekly IRS Roundup February 13 – February 17, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023.

February 13, 2023: The IRS released Internal Revenue Bulletin 2023-7, which highlights the following:

  • Revenue Procedure 2023-9: This procedure provides new rules and conditions for implementing the optional safe harbor method of accounting for real estate developers to determine when common improvement costs may be included in the basis of individual units of real property in a real property development project held for sale to determine the gain or loss from sales of those units (the Alternative Cost Method).

February 13, 2023: The IRS announced that interest rates will remain the same for the second quarter of 2023. As of April 1, 2023, the rates will be as follows:

  • Overpayments: 7%
  • Overpayments for corporations: 6%
  • Corporate overpayments for portion exceeding $10,000: 4.5%
  • Underpayments: 7%
  • Large corporate underpayments: 9%

Revenue Ruling 2023-4 contains the complete explanation of the calculations.

February 13, 2023: The IRS announced a new pilot phase for the Compliance Assurance Process (CAP) program called “Bridge Plus.” CAP is a cooperative pre-filing program for large corporate taxpayers. Taxpayers will be required to provide book-to-tax reconciliations, credit utilization and other supporting documentation shortly after their audited financial statement is finalized. An IRS team will then risk-assess the documents to determine if the taxpayer is suitable for the “Bridge Plus” phase.

February 13, 2023: The US Department of the Treasury (Treasury) and the IRS announced guidance to establish a program that would provide solar and wind power to certain low-income areas under the Inflation Reduction Act of 2022. Notice 2023-17 establishes the Low-Income Communities Bonus Credit Program and provides initial guidance for potential applicants for allocations of calendar year 2023 capacity limitation.

February 13, 2023: The IRS and the Treasury announced guidance on the Qualifying Advanced Energy Product Credit. Notice 2023-18 establishes the Section 48C(e) program to allocate $10 billion in credits ($4 billion of which may only be allocated to projects located in certain energy communities census tracts). The notice also provides initial program guidance. The goal of the program is to expand US manufacturing capacity and quality jobs for clean energy technologies (including production and recycling), reduce greenhouse gas emissions in the US industrial sector and secure domestic supply chains for critical materials (including specified critical minerals) that serve as inputs for clean energy technology production.

February 13, 2023: The IRS released Tax Tip 2023-18, reminding people that the Earned Income Tax Credit is a major tax benefit for millions of low- and moderate-income workers. Taxpayers can check their eligibility and how much they qualify for here.

February 14, 2023: The IRS released Tax Tip 2023-19, providing resources and suggestions for choosing [...]

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Weekly IRS Roundup February 6 – February 10, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 6, 2023 – February 10, 2023.

February 6, 2023: The IRS released Internal Revenue Bulletin 2023-6, which highlights the following:

  • Notice 2023-12: This notice provides updates on the corporate bond monthly yield curve and corresponding spot segment rates and the 24-month average segment rates for January 2023. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.
  • Notice 2023-13: This notice sets forth a proposed revenue procedure establishing the Service Industry Tip Compliance Agreement (SITCA) program. SITCA is a voluntary tip reporting program between the IRS and employers in the service industry that is designed to enhance tax compliance through the use of agreements instead of traditional audit techniques.
  • Revenue Procedure 2023-14: This guidance provides the tables of limitations on depreciation deductions for owners of passenger automobiles placed in during calendar year 2023 and the table dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2023.
  • Revenue Ruling 2023-3: This revenue ruling provides the applicable federal rates for federal income tax purposes for February 2023. The short-term federal interest rate is 4.47%, the mid-term is 3.82% and the long-term rate is 3.86%.

February 6, 2023: The IRS released Tax Tip 2023-14, highlighting the Taxpayer Bill of Rights, which include the Right to be Informed. Taxpayers have the right to know what they need to do to comply with the tax laws.

February 6, 2023: The IRS and the US Department of the Treasury (Treasury) announced a new program for service industry tip reporting. The proposed SITCA program is designed to take advantage of advancements in point-of-sale, time and attendance systems, and electronic payment settlement methods to improve tip reporting compliance. The proposed program would also decrease taxpayer and IRS administrative burdens and provide more transparency and certainty to taxpayers.

February 6, 2023: The IRS announced special Saturday hours for the next four months at Taxpayer Assistance Centers across the country. The Saturday hours will take place on February 11, March 11, April 8 and May 13 from 9:00 am to 4:00 pm.

February 7, 2023: The IRS released Tax Tip 2023-15, providing information to help business travelers properly claim travel business deductions.

February 8, 2023: The IRS released Announcement 2023-6, which notifies the public that it intends to issue opinion letters by February 28, 2023, for preapproved defined benefit plans that were updated for changes in plan qualification requirements and filed with the IRS during the third six-year remedial amendment cycle. This announcement also notifies the public of the date by which an adopting employer [...]

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Weekly IRS Roundup January 17 – January 20, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023.

January 17, 2023: The IRS released Internal Revenue Bulletin 2023-3, which highlights the following:

  • Notice 2023-10: This notice provides that calendar year 2022 will be a transition period for purposes of implementing the $600 reporting threshold for third-party settlement organizations. As a result, third-party organizations will not be required to report tax year 2022 transactions on Form 1099-K to the IRS or the payee for the lower $600 threshold amount unless the amount exceeds $20,000 and the number of transactions exceeds 200.
  • Notice 2023-2: This notice provides interim guidance on the new 1% excise tax on a covered corporation’s repurchases of corporate stock under Section 4501. Section 4501 was added as part of the Inflation Reduction Act of 2022 (IRA). The notice provides an exclusive list of Section 317(b) redemption transactions that are treated as Section 317(b) redemption but are not repurchases, as well as an exclusive list of economically similar transactions. The notice applies to stock repurchases and issuances of stock made after December 31, 2022.
  • Announcement 2023-1: This announcement notifies taxpayers of the applicable reference standard that must be used to determine the amount of the energy-efficient commercial building property deduction allowed under Section 179D, as amended by the IRA. This announcement identifies the existing reference standard, affirms a new one and clarifies when the two reference standards will apply.
  • Notice 2023-1: This notice informs taxpayers that the IRS and the US Department of the Treasury (Treasury) intend to propose new clean vehicle credit regulations, addressing the definitions of certain terms in Section 30D.
  • Notice 2023-03: This notice provides the 2023 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes. As of January 1, 2023, the standard mileage rates for the use of a car, van, pickup or panel truck are:
    • 5 cents per mile driven for business use
    • 22 cents per mile driven for medical or moving purposes for qualified active-duty members of the armed forces
    • 14 cents per mile driven in service of charitable organizations
  • Notice 2023-7: This notice announces that the IRS and the Treasury plan to issue guidance on the new corporate alternative minimum tax (CAMT), which imposes a 15% minimum tax on the adjusted financial statement income of large corporations for taxable years beginning after December 31, 2022. It also clarifies which corporations the CAMT applies to and how the alternative minimum tax is calculated.
  • Notice 2023-9: This notice informs taxpayers that the Treasury and the IRS have reviewed the incremental cost for all street vehicles in calendar year 2023 and the analysis shows [...]

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