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IRS roundup: March 23 – March 31, 2026

by | Apr 3, 2026 | , , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 23, 2026 – March 31, 2026.

March 23, 2026: A US Treasury Inspector General for Tax Administration (TIGTA) report found that the IRS’s approach to auditing large partnerships has been ineffective due to resource constraints and inefficient selection processes, resulting in missed audit opportunities before the statute of limitations expired. The report highlighted delays caused by duplicative review steps, prompting TIGTA to recommend improvements to streamline procedures and better target high-risk partnerships.

March 30, 2026: The IRS released its annual Advance Pricing Agreement (APA) report for 2025, summarizing the operations of the Advance Pricing and Mutual Agreement Program and transfer pricing agreement trends. The report shows that 178 APA applications were filed and 110 APAs were executed in 2025, with 622 cases pending at year-end, reflecting continued demand for advance certainty in transfer pricing. Bilateral APAs remained the dominant category, and a significant portion of cases involved jurisdictions such as India (26%) and Japan (24%) for filings, with similar trends reflected in executed agreements.

The report further indicates that most APAs covered intercompany service transactions, and the comparable profits method/transactional net margin method was used in approximately 86% of cases involving tangible and intangible property, with the operating margin as the most common profit level indicator. The average time to complete an APA was approximately 44 months overall (about 50 months for new bilateral APAs), and the typical APA term averaged six years, often including rollback years to prior tax periods.

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

Recent court decisions

March 26, 2026: The Tax Court held that taxpayers involved in a micro-captive insurance arrangement were liable for a 40% accuracy-related penalty under Internal Revenue Code (Code) § 6662(i) because the transaction lacked economic substance and was not adequately disclosed. The Court analyzed economic substance within the meaning of Code § 7701(o). The Court found that the arrangement did not meaningfully change the taxpayers’ economic position, involved a circular flow of funds among related entities, and was undertaken primarily to obtain tax benefits.

The Court noted that a “circular flow of funds among related entities” may be a strong indication that a transaction lacks economic substance. The Court further emphasized that the taxpayers failed to satisfy the adequate disclosure requirements under Code § 6662(i)(2), judging that merely reporting an “insurance” deduction without providing details of the micro-captive structure was insufficient for alerting the IRS to the potential issue.

March 26, 2026: The Tax Court rejected a $180 million conservation easement deduction, finding that the partnership’s valuation exceeded the property’s actual value and imposing a 40% gross valuation misstatement penalty. The Court rejected the taxpayer’s income-based valuation, which it considered “inherently speculative and unreliable,” and instead relied on comparable sales to determine a substantially lower value.

[...]

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IRS roundup: March 9 – March 25, 2026

by , and | Mar 26, 2026 | , , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 9, 2026 – March 25, 2026.

AI controversy developments

March 20, 2026: The US Tax Court is considering developing a disciplinary framework for the misuse of artificial intelligence (AI) in litigation following concerns raised by Judge Mark V. Holmes regarding lawyers citing AI-generated, nonexistent cases. Judge Holmes indicated that the Court is proceeding cautiously given that a large share of its docket involves pro se taxpayers and emphasized the difficulty of crafting appropriate sanctions in that context. The discussion highlights broader concerns about hallucinated authorities, potential IRS misuse of AI, and the need to protect sensitive taxpayer information as the Court balances enforcement with legitimate AI uses.

IRS guidance

March 13, 2026: The IRS announced that the secretary of the US Department of the Treasury is no longer serving as acting IRS commissioner following the expiration of authority under the Federal Vacancies Reform Act of 1998. Chief Executive Officer Frank J. Bisignano is currently leading the IRS’s day-to-day operations.

March 16, 2026: The IRS issued Revenue Ruling 2026-11, updating the rules and technical specifications for substitute versions of Form 941, Form 8974, and related schedules, including Schedules B, D, and R. The guidance provides standards for paper and computer-generated substitutes used by software developers and payroll providers and supersedes prior guidance.

March 17, 2026: The IRS issued Notice 2026-19, providing updated interest rates for pension the corporate bond monthly yield curve, spot segment rates under Internal Revenue Code (Code) § 417(e)(3), and 24-month average segment rates under Code § 430(h)(2). The notice also includes the applicable 30-year Treasury rate for February 2026 (4.76%) and related weighted average rates.

March 18, 2026: The IRS issued Notice 2026-20, extending for one additional year the temporary relief provided by Notice 2025-7, which allows taxpayers to use alternative methods to identify which units of digital assets are sold, disposed of, or transferred when held with a broker. Under this relief, taxpayers may identify units on their own books and records, including through standing orders, rather than communicating with brokers. The notice clarifies that this does not prevent taxpayers from complying with § 1.1012-1(j)(3)(ii).

March 20, 2026: The IRS issued Revenue Procedure 2026-17, providing transition relief under Code § 163(j) that allows certain taxpayers to withdraw previously irrevocable elections to be treated as electing real property trades or businesses, electing farming businesses, or excepted regulated utility trades or businesses. The guidance also permits taxpayers withdrawing those elections to make a late election out of bonus depreciation, allows taxpayers to revoke or make controlled foreign corporation group elections without regard to the 60-month limitation, and permits eligible Bipartisan Budget Act of 2015 (BBA) partnerships to file amended Forms 1065 and issue amended Schedules K-1.

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

Recent court decisions

March 9, 2026: [...]

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IRS roundup: March 3 – March 10, 2026

by , and | Mar 10, 2026 | , , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 3, 2026 – March 10, 2026.

IRS guidance

March 3, 2026: The IRS released Revenue Procedure 2026-15, which provides the inflation-adjusted luxury automobile depreciation limits under Internal Revenue Code (Code) Section 280F for passenger vehicles, including trucks and vans, placed in service in 2026 and the lease inclusion amounts for vehicles first leased in 2026. The guidance includes separate first-year depreciation caps depending on whether bonus depreciation under Section 168(k) applies.

March 4, 2026: The IRS released Revenue Procedure 2026-16, which provides information for individuals who failed to meet Code Section 911(d)(1) requirements for 2025 due to adverse conditions, listing countries and “date of departure on or after” thresholds (e.g., Haiti, Ukraine, and the Democratic Republic of the Congo, among others).

March 5, 2026: The IRS released Notice 2026-4, which requests comments on whether to modify requirements for electronic furnishing of certain payee statements, including for brokers and potentially other furnishers.

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

Recent court decisions

March 2, 2026: The US Tax Court held that a German parent company had zero basis in a $610 million promissory note that was contributed to a partnership after its wholly owned subsidiary elected to be disregarded for US tax purposes. Because the subsidiary’s retroactive “check-the-box” election caused the transaction to be treated as the parent’s contribution of its own note, the Tax Court concluded that the note had no tax basis since a taxpayer incurs no “cost” in issuing its own obligation, resulting in zero basis both in the partnership interest and in the partnership’s basis in the note.



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IRS roundup: January 21 – February 9, 2026

by , and | Feb 11, 2026 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 21, 2026 – February 9, 2026.

January 26, 2026: The IRS released Notice 2026-9, which provides a one-year extension to make certain amendments to individual retirement arrangements (IRAs), simplified employee pension arrangements, and savings incentive match plan for employees IRA plans. The new deadline is December 31, 2027. The extension gives the IRS additional time to issue model language for the various changes resulting from compliance with the SECURE 2.0 Act of 2022 and related legislation.

January 27, 2026: The IRS released Fact Sheet 2026-2, which provides updated questions and answers regarding the implementation of Executive Order 14247, Modernizing Payments To and From America’s Bank Account. The executive order advances the transition to fully electronic federal payments both to and from IRS.

January 29, 2026: The IRS announced that it is accepting applications for the Electronic Tax Administration Advisory Committee (ETAAC) through February 28, 2026. The ETAAC provides an organized public forum for discussing electronic tax administration issues, such as prevention of identity theft and refund fraud.

February 2, 2026: The IRS released Internal Revenue Bulletin No. 2026-6, which includes Announcement 2026-3. The announcement provides a copy of the arrangement entered into by the competent authorities of the United States and Spain regarding the implementation of the arbitration process provided for in paragraphs 5 and 6 of Article 26 of the US-Spain income tax treaty and its protocol.

February 2, 2026: The IRS announced that it would continue operations under the current lapse in appropriations until further notice, using funding from the Inflation Reduction Act of 2022 (IRA).

February 3, 2026: The US Department of the Treasury and the IRS issued proposed regulations regarding the clean fuel production credit enacted by the IRA and amended by the One Big Beautiful Bill Act. The new law made important changes to what is often referred to as the 45Z credit. The proposed regulations would provide rules for determining clean fuel production credits. They also would amend three sets of final regulations: the elective payment election regulations and the credit transfer election regulations (to clarify language relating to ownership of clean fuel production facilities) and the federal excise tax registration regulations (to make them clearer and more consistent with the clean fuel production credit registration requirements in these proposed regulations). The proposed regulations would affect domestic producers of clean transportation fuel, taxpayers that may claim a credit for a related producer’s fuel, and excise tax registrants. Comments must be received by April 6, 2026. There is a public hearing that will be held on May 28, 2026, and requests to speak at the public hearing will be accepted until May 26, 2026.

Recent court decisions

January 28, 2026: The US Tax Court issued its opinion in Aventis Inc. v. Commissioner, rejecting Aventis’s attempt to treat [...]

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IRS roundup: November 7 – November 24, 2025

by , , , , and | Dec 2, 2025 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 7, 2025 – November 24, 2025.

November 10, 2025: The IRS released Internal Revenue Bulletin No. 2025-46, which includes proposed regulations 109742-25. The proposed regulations would remove a rule in previous final regulations that uses the shareholders of certain domestic corporations to determine whether foreign persons hold – directly or indirectly – stock in a domestically controlled qualified investment entity (QIE). If a QIE was not domestically controlled following the changes from the proposed regulations, stock owned by foreign persons in a QIE would qualify as a US real property interest.

November 10, 2025: The IRS released Revenue Procedure 2025-31, providing guidance on a safe harbor that allows trusts qualifying as investment trusts under Section 301.7701-4(c) and as grantor trusts to stake digital assets without losing their tax status and offering a limited period for existing trusts to amend their governing instruments to meet the safe harbor requirements.

November 13, 2025: The IRS released Notice 2025-67, which announces the annual cost-of-living adjustments to the limits on benefits and contributions for qualified retirement plans under Section 415 of the Internal Revenue Code (Code). These adjustments, required by Section 415(d), follow procedures similar to those used for Social Security benefit updates and apply to certain amounts under deferred compensation plans.

November 13, 2025: The IRS released Revenue Ruling 2025-22, announcing that interest rates will remain unchanged for the calendar quarter beginning January 1, 2026. The rates are as follows:

  • 7% for individual overpayments and 6% for corporate overpayments
  • 5% on the portion of a corporate overpayment exceeding $10,000
  • 7% for underpayments and 9% for large corporate underpayments

Under the Code, these rates are recalculated quarterly based on the federal short-term rate. For noncorporate taxpayers, both overpayment and underpayment rates equal the federal short-term rate plus three percentage points. For corporations, the underpayment rate is also the short-term rate plus three points while the overpayment rate is the short-term rate plus two points. Large corporate underpayments add five points, and corporate overpayments exceeding $10,000 add 0.5 points. The current rates are based on the federal short-term rate determined in October 2025.

November 19, 2025: The IRS announced that it would resume its regular activities following the 2025 lapse in appropriations during the government shutdown. In its announcement, the IRS included specific frequently asked questions regarding the resumption of regular activities for audits, collections, and appeals and stated that determination letter applications for tax exempt and government entities would resume.

Recent court decisions

November 5, 2025: The US District Court for the Northern District of Texas issued an opinion in Ryan, LLC v. IRS. Check out our recent insight on the case, including an analysis of the district court’s holdings and practice points for taxpayers.

November 12, 2025: The US [...]

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Tax Court confirms codified economic substance doctrine requires threshold relevancy determination, upholds 40% strict-liability penalty

by and | Nov 24, 2025 | , ,

Patel v. Commissioner, 165 T.C. No. 10 (Nov. 12, 2025), gave the US Tax Court its “first opportunity to examine when the codified economic substance doctrine applies.” Patel at *16. The Tax Court made two key holdings:

  • Section 7701(o) requires a relevancy determination that “is not coextensive with the two-part test set forth in section 7701(o)(1)(A) and (B).” Patel at *17.
  • Adequate disclosure to reduce the 40% economic substance penalty imposed by sections 6662(b)(6) and (i) must be made at the time the return is filed and not at a later time. Patel at *30.

Relevancy determination

Section 7701(o) provides:

Sec. 7701(o). Clarification of economic substance doctrine.—

 

(1) Application of doctrine.—In the case of any transaction to which the economic substance doctrine is relevant, such transaction shall be treated as having economic substance only if—

 

(A) the transaction changes in a meaningful way (apart from Federal income tax effects) the taxpayer’s economic position, and

 

(B) the taxpayer has a substantial purpose (apart from Federal income tax effects) for entering into such transaction.

While the Internal Revenue Service (IRS) endorses a seemingly limitless application of the codified economic substance doctrine, taxpayers contend that it does not apply to every transaction. Rather, the plain language of section 7701(o)(1) requires a threshold relevancy determination. If the economic substance doctrine is not relevant, the inquiry ends.

There are very few cases that have considered whether section 7701(o) requires a threshold relevancy determination. And those that have found that section 7701(o) does not impose a separate relevancy requirement. See Liberty Global, Inc. v. United States, No. 20-cv-63501, 2023 WL 8062792 (D. Colo. Oct. 31, 2023); Chemoil Corp. v. United States, No. 19-cv-6314, 2023 WL 6257928 (S.D.N.Y. Sept. 26, 2023). While Liberty Global was appealed to the US Court of Appeals for the Tenth Circuit – and many speculate the Tenth Circuit may clarify that there is a relevancy requirement – the Tax Court beat the appellate court to the punch.

The Tax Court’s holding had solid statutory support. The plain language of section 7701(o)(1) states: “In the case of any transaction to which the economic substance doctrine is relevant…” After quoting these words, the Tax Court stated, “we easily conclude that the statute requires a relevancy determination. To put it plainly—the statute says so, right there, on its face.” Patel at *17.

Adequate disclosure of transactions

The second key holding in Patel is that the taxpayers in the case are liable for a 40% penalty for engaging in a transaction that lacks economic substance that was not adequately disclosed. Section 6662(b)(6) imposes a 20% penalty on transactions that lack economic substance. This penalty is increased to 40% under section 6662(i) if the transaction is not adequately disclosed.[1]

In the current wave of economic substance challenges, it is unclear what constitutes adequate disclosure under section 6662(i) such that the 20% (instead of the 40%) penalty applies. Based on current audit activity, [...]

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IRS roundup: September 19 – October 1, 2025

by , , , and | Oct 8, 2025 | , , , ,

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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IRS roundup: August 28 – September 15, 2025

by , , , and | Sep 18, 2025 | , , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 28, 2025 – September 15, 2025.

August 28, 2025: The IRS issued Revenue Procedure 2025-28, providing guidance on making certain elections for domestic research or experimental expenditures under § 70302(f) of the One Big Beautiful Bill Act (OBBBA). Revenue Procedure 2025-28 specifically modifies procedures under Internal Revenue Code (Code) § 446 and Treasury Regulation § 1.446-1(e) for obtaining automatic consent from the commissioner of the Internal Revenue to:

  • Change methods of accounting for research or experimental expenditures under § 174, as amended by the Tax Cuts and Jobs Act of 2017
  • Change methods of accounting to comply with §§ 174 and 174A, as amended by OBBBA.

Revenue Procedure 2025-28 also prescribes the procedure for electing to amortize domestic research or experimental expenditures paid or incurred in the taxable years beginning after December 31, 2024, under Code § 174A(c).

September 2, 2025: The IRS issued Tax Tip 2025-59, reminding employers that they can use educational assistance programs to help employees pay for various educational expenses for undergraduate- or graduate-level studies. These programs can help pay for books, equipment, supplies, tuition, and other fees, as well as for qualified education loans. This tax-free benefit is allowed only up to $5,250 per employee per year and does not include meals, lodging, or transportation.

September 3, 2025: In Medtronic, Inc. v. Commissioner, the US Court of Appeals for the Eighth Circuit vacated the US Tax Court’s order, rejecting the Tax Court’s three-step unspecified method to value the arm’s length royalty rate for intercompany licensing agreements. The Eight Circuit also held that the Tax Court incorrectly rejected the application of the comparable profits method, explaining that, on remand, the Tax Court should consider whether the proposed comparable companies were “sufficiently similar” to Medtronic Puerto Rico.

September 15, 2025: The IRS released Internal Revenue Bulletin 2025–38, which includes Notice 2025-38. This notice republishes the inflation adjustment factor and the clean electricity production credit allowable under Code § 45Y for the 2025 calendar year. The inflation adjustment factor – and applicable amounts allowable for the 2025 calendar year – are used to determine the amount of Code § 45Y credits that may apply to calendar year 2025 sales, consumption, or storage of electricity produced at a qualified facility in the United States.

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



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IRS Roundup May 15 – June 2, 2025

by , , , and | Jun 5, 2025 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025.

IRS GUIDANCE

May 15, 2025: The IRS issued Notice 2025-29, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) § 417(e)(3), and the 24-month average segment rates under Code § 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code § 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code § 431(c)(6)(E)(ii)(I).

May 15, 2025: The IRS issued Revenue Ruling 2025-12, providing prescribed rates for federal income tax purposes for June 2025, including, but not limited to:

  1. Short-, mid-, and long-term applicable federal rates for June 2025 for purposes of Code § 1274(d)
  2. Short-, mid-, and long-term adjusted applicable federal rates for June 2025 for purposes of Code § 1288(b)
  3. The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code § 382(f)
  4. The federal rate for determining the present value of an annuity, an interest for life, or for a term of years, or a remainder or a reversionary interest for purposes of Code § 7520.

May 19, 2025: The IRS released Internal Revenue Bulletin 2025-21. It includes Revenue Procedure 2025-19, which provides the 2026 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under Code § 223, as well as the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements under Code § 54.9831-1(c)(3)(viii). Revenue Procedure 2025-19 is effective for HSAs for the 2026 calendar year and for excepted benefit health reimbursement arrangements beginning in 2026.

May 22, 2025: The IRS issued a notice to US taxpayers living or working abroad, encouraging them to file their 2024 federal income tax returns by June 16, 2025.

June 2, 2025: The IRS issued Notice 2025-27, providing interim guidance on the application of the corporate alternative minimum tax (CAMT), as well as relief from certain additions to tax for a corporation’s underpayment of estimated tax under Code § 6655. Among other things, this notice also provides an optional simplified method for determining applicable corporation status and waives certain additions to tax under Code § 6655 concerning a corporation’s CAMT liability under Code § 55. The US Department of the Treasury (Treasury) and the IRS also plan on issuing a notice of proposed rulemaking, revising the CAMT proposed regulations in § 2.02(2) of this notice to include a method for determining applicable corporation status.

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

TAX CONTROVERSY DEVELOPMENTS

On May 22, 2025, the US Tax Court issued its opinion in Facebook Inc. v. Commissioner.

THE “BIG, BEAUTIFUL BILL”

The “
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IRS Roundup February 10 – 14, 2025

by , , and | Feb 25, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025.

TAX-CONTROVERSY-RELATED DEVELOPMENTS

The previous IRS Roundup provided general coverage of the proposed Taxpayer Assistance and Service (TAS) Act. This post highlights Section 310 of the TAS Act, which would give the US Tax Court authority to hear general refund suits similar to those currently heard in the US district courts and the US Court of Federal Claims.

Historically, taxpayers could only contest their tax liability by first paying the tax and then suing for a refund in a district court or the Court of Federal Claims. The Board of Tax Appeals (BTA), the forerunner to the Tax Court, was created in 1924 to give taxpayers a prepayment forum in which to dispute their tax liability. The BTA was initially proposed to have general refund suit jurisdiction, but Congress limited its jurisdiction to cases brought in response to a notice of deficiency. Several proposals have been made over the years to expand the jurisdiction of the BTA and (now) the Tax Court to include general refund suits, which they would share with the district courts and the Court of Federal Claims. Recent support for this approach has come from National Taxpayer Advocates Nina Olson and Erin Collins. As one commentator noted, the proposed expansion to the Tax Court’s jurisdiction has the potential to improve access to justice for taxpayers and reduce the burden on district courts and the Court of Federal Claims.

IRS GUIDANCE

February 12, 2025: The IRS issued Revenue Procedure 2015-16, which provides depreciation deduction limitations for “passenger automobiles” (including trucks and vans) placed in service during 2025 and income inclusion amounts for lessees of such vehicles. The revenue procedure also includes two tables detailing depreciation limits based on whether the Internal Revenue Code (Code) § 168(k) additional first-year depreciation deduction applies. Additionally, the revenue procedure outlines the inflation adjustment calculation for these limits and provides a table for determining income inclusions for leased passenger automobiles. The tables reflect the automobile price inflation adjustments required by Code § 280F(d)(7).

February 12, 2025: The IRS released Notice 2025-14, which provides guidance on the corporate bond monthly yield curve, spot segment rates under Code § 417(e)(3), and 24-month average segment rates under Code § 430(h)(2). The notice also provides guidance as to the interest rate on 30-year Treasury securities under Code § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under Code § 431(c)(6)(E)(ii)(I).

February 13, 2025: The IRS issued Revenue Procedure 2025-15, which provides discount factors for the 2024 accident year for insurance companies to use when computing discounted unpaid losses under Code § 846 and discounted estimated salvage recoverable under Code § 832. The revenue procedure includes tables with discount factors for various lines of business (both short- and long-tail) and addresses the use of [...]

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