qualified opportunity zones Archives

IRS roundup April 1 – April 9, 2026

by Kai M. Fenty and Edward L. Froelich | Apr 13, 2026 | Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2026 – April 9, 2026.

April 3, 2026: The White House proposed significant budget cuts to the Treasury Inspector General for Tax Administration (TIGTA), reducing its funding by nearly 17% for fiscal year 2027 to the lowest level since 2007. TIGTA warned that the cuts, combined with recent staffing losses, could lead to a 35% reduction in oversight activities at a time when risks at the IRS are increasing and have already forced the watchdog to cancel dozens of audits and reviews.

The proposal comes alongside broader reductions to IRS funding and staffing, including cuts to enforcement resources, raising concerns among practitioners that diminished oversight could weaken accountability and tax administration – particularly as the IRS undergoes workforce reductions and expands its use of new technologies, such as artificial intelligence.

April 6, 2026: Taxpayers are urging the Supreme Court of the United States to consider whether the Seventh Amendment guarantees a right to a jury trial for IRS civil penalties in Hirsch v. US Tax Court, arguing that the Court’s 2024 decision in SEC v. Jarkesy should apply in the tax context. Hirsch arises from fraud penalties exceeding $15 million that were assessed against taxpayers who allegedly misrepresented US Virgin Islands residency. A ruling in the plaintiffs’ favor could significantly alter IRS enforcement by making penalties harder to impose and potentially slowing audits and collections.

To date, courts have largely rejected similar arguments, relying on the “public rights” doctrine and long-standing precedent treating tax penalties as remedial rather than punitive, but practitioners note that the issue is gaining traction. If the Supreme Court requires jury trials for certain tax penalties, it could reshape the balance between taxpayers and the IRS, particularly for high-dollar cases, while raising concerns about reduced deterrence and increased administrative burdens on the agency.

April 6, 2026: The IRS issued Revenue Procedure 2026-14, providing guidance for states to nominate population census tracts for designation as qualified opportunity zones, effective January 1, 2027, under §§ 1400Z-1 and 1400Z-2, as amended by the One Big Beautiful Bill Act. The revenue procedure outlines eligibility requirements for low-income communities, limits designations to 25% of eligible tracts per state, and establishes deadlines for nominations and US Department of the Treasury certification.

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

Proposed changes to the Voluntary Disclosure Program (VDP)

April 6, 2026: The IRS proposed updates to VDP that would replace the one-time 75% civil fraud penalty with 20% accuracy-related penalties applied annually over the six-year disclosure period while also imposing a new requirement that taxpayers pay all taxes, penalties, and interest and file all required returns within 90 days of conditional acceptance. Practitioners generally support the move away from the 75% penalty but warn that the cumulative penalties (along [...]

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Weekly IRS Roundup June 1 – June 5, 2020

by McDermott Will & Schulte | Jun 8, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

June 2, 2020: The IRS reminded taxpayers who live and work abroad that they have until July 15, 2020, to file their 2019 federal income tax return and pay any tax due. Typically, the deadline for such returns is June 15.

June 3, 2020: The IRS issued Notice 2020-42 to provide temporary relief from the physical presence requirement in Treasury Regulations § 1.401(a)-21(d)(6) for participant elections required to be witnessed by a plan representative or a notary public, including a spousal consent required under IRC § 417.

June 4, 2020: The IRS issued Notice 2020-39 and updated the Qualified Opportunity Zones frequently asked questions (FAQs). Notice 2020-39 answers questions regarding relief from certain requirements under IRC § 1400Z-2, particularly providing that if a taxpayer’s 180th day to invest in a qualified opportunity zone would have fallen on or after April 1, 2020, and before December 31, 2020, the taxpayer now has until December 31, 2020, to invest that gain into a qualified opportunity fund (QOF). In addition, Notice 2020-39 provides that the period between April 1, 2020, and December 31, 2020, is suspended for purposes of the 30-month period during which property may be substantially improved.

June 4, 2020: The IRS announced that the Office of Chief Counsel will be expanding its Virtual Settlement Days program. Settlement Days events are organized in effort to resolve US Tax Court cases by providing taxpayers not represented by counsel the opportunity to receive free tax advice from certain pro bono groups such as the Low Income Taxpayer Clinics (LITCs) and American Bar Association (ABA).Through this program, taxpayers can also discuss their Tax Court cases and resolve related tax issues with members of the IRS Office of Chief Counsel, the Independent Office of Appeals and Collection.Due to COVID-19, Settlement Days events are now virtual and allow for taxpayers and volunteers to join from any location.

June 5, 2020: The IRS issued Notice 2020-43 to seek public comment on a proposed requirement for partnerships to use only one of two alternative methods described in Notice 2020-43 to satisfy the Tax Capital Reporting Requirement with respect to partnership taxable years that end on or after December 31, 2020. The two methods that a partnership may use to report, for each partner, are either (i) the partner’s basis in its partnership interest, reduced by the partner’s allocable share of partnership liabilities, as determined under IRC § 752 (Modified Outside Basis Method); or (ii) the partner’s share of previously taxed capital, as calculated under a modified version of Treas. Reg. § 1.743-1(d) (Modified Previously Taxed Capital Method).

June 5, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, [...]

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Weekly IRS Roundup July 9 – 13, 2018

by McDermott Will & Emery | Jul 16, 2018 | IRS Guidance, Uncategorized

Presented below is our weekly roundup for July 9 – 13, 2018 on significant IRS matters.

July 9, 2018: The IRS released Internal Revenue Bulletin No. 2018-28 including: Notice 2018-48 (lists the population census tracts designated as qualified opportunity zones); Notice 2018-59 (provides two methods for taxpayers to begin construction for the investment tax credit under Section 48); Announcement 2018-11 (Office of Professional Responsibility [OPR] announces recent disciplinary sanctions); Rev. Rul. 2018-20 (rendering obsolete several previous revenue rulings); and Rev. Proc. 2018-35 (modifying Rev. Proc. 2018-31 regarding accounting methods for citrus plant replanting costs).

July 11, 2018: The IRS issued final regulations (T.D. 9834) addressing inversion transactions structured to avoid the purposes of sections 7874 and 367 and other post-inversion tax avoidance transactions.

July 13, 2018: The IRS issued proposed regulations (REG-103474-18) related to the Code section 6695(g) return preparer penalty amending previous guidance to reflect changes made by 2017 federal tax reform.

July 13, 2018: The IRS released it weekly list of written determination (e.g., Private Letter Rulings, Technical Advice Memorandum and Chief Counsel Advice).

Special thanks to Christy Vouri-Misso and Greg Berson in our DC office for this week’s roundup.