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Weekly IRS Roundup April 15 – April 19, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15, 2024 – April 19, 2024.

April 15, 2024: The IRS released Internal Revenue Bulletin 2024-16, which includes the following:

  • Announcement 2024-16, which describes the experience, structure and activities of the Advance Pricing and Mutual Agreement Program during calendar year 2023.
  • Proposed regulations, which would revise regulations pertaining to the advance notice provided to taxpayers before the IRS contacts third parties. These proposed regulations are intended to conform to the new statutory language of Section 7602(c) of the Internal Revenue Code (Code), enacted as part of the Taxpayer First Act of 2019, and provide exceptions to the 45-day advance notice requirement where delaying contact with third parties for 45 days after providing notice to the taxpayer would impair tax administration.
  • Announcement 2024-17, which contains corrections to proposed regulations under Code Sections 761 and 6417 that address certain electricity production credits.
  • Notice 2024-30, which expands the Nameplate Capacity Attribution Rule under Section 4.02(1)(b) of Notice 2023-29 to include additional attribution property. The notice also adds two 2017 North American Industry Classification System industry codes to the table in Section 3.03(2) of Notice 2023-29, which are relevant for purposes of determining the Fossil Fuel Employment rate (as defined in Section 3.03(2) of Notice 2023-29).
  • Notice 2024-32, which addresses the eligibility of loan borrowers through State Supplemental Loan programs and the loan size limitation for State Supplemental Loans. The notice also provides guidance on whether an issue of state or local bonds, the proceeds of which are used to finance or refinance qualified student loans or to finance qualified mortgage loans, is a refunding issue.
  • Proposed regulations, which would identify certain charitable remainder annuity trust transactions and substantially similar transactions as listed transactions. Material advisors and certain participants in these listed transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
  • Revenue Procedure 2024-19, which provides the process under Code Section 48(e) to apply for an allocation of environmental justice solar and wind capacity limitation as part of the low-income communities bonus credit program for 2024. The revenue procedure also describes how the capacity limitation for the 2024 program year will be divided across the facility categories described in Sections 48(e)(2)(A)(iii) and 1.48(e)-1(b)(2), the Category 1 sub-reservation described in Section 1.48(e)-1(i)(1) and the additional selection criteria application options described in Section 1.48(e)-1(h).
  • Revenue Ruling 2024-8, which provides the terminal charge and Standard Industry Faire Level mileage rates used for valuing noncommercial flights on employer-provided aircraft.

April 15, 2024: The IRS announced it has answered over one million more taxpayer phone calls this tax season, helped over 170,000 more people in person and saw 75 million more IRS.gov visits [...]

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Weekly IRS Roundup July 24 – July 28, 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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