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Weekly IRS Roundup September 12 – September 16, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022.

September 12, 2022: The IRS released Internal Revenue Bulletin 2022-37, which highlights the following:

  • Treasury Decision 9965: These regulations establish certain requirements regarding the implementation of protections against balance billing provided under the No Surprise Act.
  • Notice 2022-37: This guidance assists taxpayers in complying with the final regulations under Section 871(m). The US Department of the Treasury (Treasury) and the IRS intend to amend Section 871(m) regulations, which will delay the effective date of certain rules in the final regulations and extend the phase-in period provided in Notice 2020-2 for two years.

September 12, 2022: The IRS released COVID Tax Tip 2022-139, reminding taxpayers of recently issued Notice 2022-36, which provides penalty relief from certain failure to file penalties in taxable years 2019 and 2020. The relevant penalties will be waived, abated, refunded or credited. The relief is designed to help struggling taxpayers affected by the COVID-19 pandemic and to allow the IRS to focus resources on processing backlogged tax returns and taxpayer correspondence.

September 12, 2022: The Treasury Inspector General for Tax Administration (TIGTA) released the Fiscal Year 2022 Statutory Review of Compliance With Notice of Federal Tax Lien Filing Due Process Procedures. TIGTA is required to determine annually whether lien notices issued by the IRS comply with the legal requirements set forth in the Internal Revenue Code. TIGTA recommended that the Director of Collection Policy for the Small Business/Self-Employed Division (1) reinforce Internal Revenue Manual (IRM) guidance to ensure that taxpayers’ representatives are notified of Notice of Federal Tax Lien filings and (2) correct an IRM reference on Written Communication to a Taxpayer’s Authorized Representative. The IRS agreed.

September 12, 2022: TIGTA released its report entitled, Reliance on Self-Certifications Resulted in Federal Agencies Awarding Contracts and Grants to Entities With Delinquent Federal Taxes; However, the IRS Is Making Progress on Establishing the Federal Contractor Tax Check System. TIGTA performed this audit because in Calendar Years 2015 and 2016, federal contracts were awarded to thousands of contractors with unpaid taxes that were most likely delinquent. Between October 2018 and December 2019, the federal government awarded 2.1 million federal contracts to more than 83,000 awardees. More than 3,000 contractors that received contracts owned $621.8 million in delinquent federal taxes, and 938 grantees received $22.7 billion in federal grants while owning $269.2 million in delinquent federal taxes.

September 12, 2022: The IRS issued minor corrections to Treasury Decision 9964, originally published August 16, 2022. The regulations define guidance for states regarding the process by which they may obtain or inspect certain returns and return information for the purpose of administering state laws governing certain tax-exempt organizations and their activities.

September [...]

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Weekly IRS Roundup August 23 – August 27, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 23, 2021 – August 27, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 23, 2021: The IRS announced that the application period for the 2022 Compliance Assurance Process (CAP) program will run September 1 to November 1, 2021. Acceptance notices will be delivered in February 2022. The CAP program employs real-time issue resolution between taxpayers and the IRS to improve federal tax compliance by resolving problems prior to the filing of a tax return. To be eligible, applicants must: (1) have assets worth $10 million or more; (2) be a US publicly traded corporation with a legal requirement to prepare and submit US Securities and Exchange Commission (SEC) Forms 10-K, 10-Q and 8-K and (3) not under investigation by—or in litigation with—any government agency that would limit the IRS’s access to current tax records. The IRS’s CAP webpage can be found here.

August 25, 2021: The IRS announced that interest rates for the calendar quarter starting October 1, 2021, will remain the same and will be issued in Rev. Rul. 2021-17, dated September 13, 2021.

August 27, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Emily Mussio in our Chicago office for this week’s roundup.




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Weekly IRS Roundup August 20 – 24, 2018

Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 20 – 24, 2018:

August 21, 2018: The IRS and Treasury released Notice 2018-67, which provides guidance regarding separately calculating the unrelated business taxable income (UBTI) of each trade or business conducted by a tax-exempt entity. Section 512(a)(6), enacted as part of tax reform, requires this separate calculation by tax-exempt organizations with more than one unrelated trade or business.

August 21, 2018: The IRS and Treasury released Notice 2018-68, which provides guidance regarding new section 162(m). Section 162(m), enacted as part of tax reform, limits the deduction for compensation paid by a publicly traded corporation to a covered employee. The notice provides guidance regarding the “grandfather” exception for certain compensation arrangements in effect on November 2, 2017. See our commentary for more information.

August 22, 2018: The IRS released Revenue Procedure 2018-44, which provides guidance regarding accounting method changing resulting from the revocation or termination of an entity’s S corporation status. Revenue Procedure 2018-44 adds such accounting method changes to the list of “automatic changes” listed in Revenue Procedure 2018-31.

August 22, 2018: The IRS published a draft Form 8992 for computing global low-taxed intangible income and a draft Form 8993 for computing foreign derived intangible income.

August 23, 2018: The IRS published proposed regulations providing guidance regarding the availability of a charitable deduction when the taxpayer also receives (or expects to receive) a state or local tax credit for the contribution.

August 24, 2018: The IRS made it clear that US citizens and residents that are contractors or employees of contractors supporting US Armed Forces are eligible for the section 911 foreign earned income exclusion.

August 24, 2018: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Kevin Hall in our DC office for this week’s roundup.




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