special per diem rates Archives | TAX CONTROVERSY 360

IRS roundup: September 19 – October 1, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney | Oct 8, 2025 | Appellate Courts, Court Procedure Matters, IRS Guidance, Tax Reform, Transfer Pricing Resource

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for September 19, 2025 – October 1, 2025.

September 19, 2025: The US Department of the Treasury (Treasury) and the IRS issued proposed regulations, providing guidance on the “no tax on tips” provision of the One Big Beautiful Bill Act. The proposed regulations define “qualified tips” and identify which occupations customarily and regularly receive tips on or before December 31, 2024.

September 23, 2025: The IRS issued Notice 2025-54, providing guidance on the 2025 – 2026 special per diem rates for taxpayers when determining their ordinary and necessary business expenses incurred while traveling away from home, including meal and incidental expenses rates, rates for the incidental expenses only deduction, and rates for (and a list of) high-cost localities for purposes of the high-low substantiation method.

September 29, 2025: The IRS issued Revenue Procedure 2025-30, providing updated procedures for taxpayers requesting private letter rulings from the IRS after September 29, 2025, regarding transactions intended to qualify under Internal Revenue Code § 3551. This guidance specially provides details on the representations, information, and analysis taxpayers should submit when requesting these rulings.

September 30, 2025: The IRS issued Notice 2025-46 and Notice 2025-49, providing guidance on the application of the corporate alternative minimum tax (CAMT).

Notice 2025-46 provides interim guidance to domestic corporate transactions, financially troubled companies, and tax consolidated groups. This notice also announces the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 6 of this notice. The proposed regulations will reduce compliance burdens related to, and costs associated with, application of the CAMT.

Notice 2025-49 provides interim guidance regarding application of the CAMT as it relates to §§ 55, 56A, and 59. This notice also announced the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 10 of this notice.

October 1, 2025: The Treasury and the IRS issued final regulations, providing guidance on interest capitalization requirements on designated property. The final regulations specifically remove the associated property rule (including similar rules in existing regulations), modifies how “improvement” is defined when applying those similar rules, and primarily affects taxpayers making improvements to real or tangible personal property if those improvements are the production of designated property.

October 1, 2025: The US Court of Appeals for the Eighth Circuit released its opinion in 3M Company v. Commissioner. The Eighth Circuit reversed the US Tax Court’s decision that 3M must pay taxes on royalties – that it could not legally receive – from a Brazilian subsidiary and remanded the Tax Court’s decision with instructions to redetermine 3M’s tax liability. Relying [...]

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Weekly IRS Roundup September 16 – September 20, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 27, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16, 2024 – September 20, 2024.

September 16, 2024: The IRS released Internal Revenue Bulletin 2024-38, which include proposed regulations that detail the clean electricity low-income communities bonus credit program under § 48E of the Internal Revenue Code (Code). The regulations outline definitions, requirements, and procedures for applicants seeking to increase their clean electricity investment credit for the taxable year in which the facility is placed in service.

September 16, 2024: The IRS released Revenue Ruling 2024-21, which provides the October 2024 applicable federal rates.

September 17, 2024: The IRS appointed 10 new members to the Electronic Tax Administration Advisory Committee, which serves as a public forum for discussing electronic tax administration issues. These new members, which include state tax officials, cybersecurity experts, and tax professionals, bring diverse expertise from various fields.

September 17, 2024: The IRS recognized its Taxpayer Services Chief for their leadership and efforts to enhance taxpayer services and digital initiatives.

September 18, 2024: The IRS released proposed regulations, which provide a federal income tax credit of up to 30% for costs associated with installing qualified alternative fuel vehicle refueling property in low-income or non-urban census tracts under Code § 30C. The regulations outline eligibility criteria, application procedures, and specific requirements for claiming the credit.

September 18, 2024: The IRS released Notice 2024-64, which modifies Notice 2024-20 by updating the mapping tools used to identify eligible census tracts for the alternative fuel vehicle refueling property credit and extends the period during which taxpayers can rely on these tools. This notice is effective September 18, 2024.

September 18, 2024: The IRS released Notice 2024-67, which provides the 24-month average corporate bond segment rates for September 2024, the yield curve and segment rates for single-employer plans, and the 30-year Treasury securities interest rates.

September 18, 2024: The IRS released Revenue Procedure 2024-37, which provides guidance for issuers of tax-exempt and other tax-advantaged bonds on the procedures for filing claims to recover overpayments of rebate, the penalty in lieu of rebate provisions, and the yield reduction payment provisions under Code § 148. The guidance applies to claims filed on or after October 18, 2024.

September 18, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Pennsylvania that were affected by Tropical Storm Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency, including individuals and households that reside or have a business in Lycoming, Potter, Tioga and Union Counties.

September 19, 2024: The IRS announced it is offering a free webinar on September 26, [...]

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Weekly IRS Roundup October 10 – October 14, 2022

by McDermott Will & Emery | Oct 17, 2022 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 10, 2022 – October 14, 2022.

October 11, 2022: The IRS released Internal Revenue Bulletin 2022-41, which highlights the following:

Notice 2022-42: This notice announces that the IRS and the US Department of the Treasury (Treasury) intend to amend the regulations under Section 901 with respect to the application of the noncompulsory payment regulations to certain amended Puerto Rico tax decrees.

Notice 2022-44: This notice provides annual awareness of the 2022-2023 special per diem rates for taxpayers to use when substantiating the amount of business expenses incurred while traveling away from home. The guidance addresses (1) the special transportation industry meal and incidental expenses rates, (2) the rate for the incidental expenses only deduction and (3) the rates and list of high-cost localities for purposes of the high-low substantiation method.

Revenue Procedure 2022-19: This revenue procedure provides guidance to allow S corporations and their shareholders to resolve frequently encountered issues with certainty and without requesting a private letter ruling issued by the IRS.

October 11, 2022: The IRS issued Notice 2022-41, which expands the application of permitted change-in-status rules for health coverage under a Section 125 cafeteria plan. This guidance addresses when a plan participant may want to revoke the employee’s election under the cafeteria plan for family coverage under a group health plan (other than a flexible spending arrangement) in order to allow one or more family members to enroll in a Qualified Health Plan through a Health Insurance Exchange in the individual market.

October 11, 2022: The IRS announced that seminars from the 2022 IRS Nationwide Tax Forum are now available online. The platform offers 18 self-study seminars, including ones on the following topics:

IRS Commissioner Chuck Rettig’s Keynote Address
Tax Law Changes for Tax Year 2022 – in English and Spanish
Professional Responsibility Obligations (Ethics) – in English and Spanish
Tax Treatment of Digital Assets
Tax-Exempt Organizations Update
Emerging Cyber Crimes – in English and Spanish

October 11, 2022: The IRS announced that it is expanding dyed diesel penalty relief in response to Hurricane Ian. The IRS will not impose a penalty when dyed diesel fuel with a sulfur content that does not exceed 15 parts-per-million is sold for use or used on highways in the state of Florida. The relief began on September 28, 2022, and lasts through October 19, 2022. The penalty relief previously only applied to emergency vehicles.

October 11, 2022: The IRS issued a statement related to uncertain tax positions (UTP) reporting. Draft changes to the Schedule UTP and the UTP instructions are available at Draft Task Forms. The draft changes are intended to improve the form’s usefulness by incorporating additional relevant examples and [...]

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