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Weekly IRS Roundup September 20 – 24, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 22, 2021: The US Department of the Treasury (Treasury) and the IRS published final regulations under IRC § 301. The regulations update existing regulations under IRC § 301 to reflect statutory changes made by the Technical and Miscellaneous Revenue Act of 1988, which changes provide that the amount of a distribution of property made by a corporation to its shareholder is the fair market value of the distributed property. The regulations affect shareholders that receive a distribution of property from a corporation.

September 22, 2021: The IRS introduced a new webpage that provides information to taxpayers whose large refunds are subject to further review by the Joint Committee on Taxation.

September 22, 2021: The IRS released instructions for Form 1065, U.S. Return of Partnership Income, to reflect the addition of Schedules K-2 and K-3. The new schedules assist partnerships in providing partners with the information necessary for the partners to complete their returns with respect to the international tax provisions of the IRC. The IRS also released related instructions for Form 1120-S, U.S. Income Tax Return for an S Corporation, to reflect Schedules K-2 and K-3, which assist with reporting items of international tax relevance from the operation of an S corporation.

September 24, 2021: The Treasury Department and the IRS published final regulations under IRC under sections 250 and 951A addressing the calculation of qualified business asset investment for qualified improvement property under the alternative depreciation system. The regulations also deal with the transition rules relating to the impact on loss accounts of net operating loss carrybacks allowed by the Coronavirus Aid, Relief, and Economic Security Act. The final regulations affect United States shareholders of controlled foreign corporations, domestic corporations eligible for the section 250 deduction and taxpayers that claim credits or deductions for foreign income taxes.

September 24, 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 Robbie Alipour in our Chicago office for this week’s roundup.




Weekly IRS Roundup September 13 – 17, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 13, 2021 – September 17, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 13, 2021: The IRS issued a news release concerning resources available to help small businesses learn their employer tax responsibilities and to help their employees.

September 13, 2021: The IRS postponed various tax filing and payment deadlines for victims of Hurricane Ida in parts of Pennsylvania. Victims now have until January 3, 2022, to file various individual and business tax returns and make tax payments.

September 14, 2021: The US Department of the Treasury (Treasury) and the IRS published a notice and request for comments concerning the interest rates and appropriate foreign loss payment patterns for determining the qualified insurance income of certain controlled corporations under IRC § 954(f). Written comments should be received on or before November 15, 2021.

September 14, 2021: The IRS issued a news release reminding employers about a valuable tax credit available to them for hiring long-term unemployment recipients and other groups of workers facing significant employment barriers.

September 15, 2021: The Treasury and the IRS published a notice and request for comments concerning forms related to foreign account tax compliance act registration (FATCA), including Forms 8966, 8957, 8966-C, 8809-I and 8508-I. Written comments should be received on or before November 15, 2021.

September 16, 2021: The IRS issued a news release reminding taxpayers who asked for an extension to file their 2020 return that they should file on or before October 15, 2021, to avoid the penalty for filing late.

September 16, 2021: The IRS published a practice unit concerning the limitation of exchange gain or loss on payment or disposition of debt instrument.

September 16, 2021: The Treasury and the IRS published a notice and request for comments on Revenue Procedure 99-17 that prescribes the time and manner for dealers in commodities and traders in securities or commodities to elect to use the mark-to-market method of accounting under IRC § 475(e) or IRC § 475(f). Written comments should be received on or before November 15, 2021.

September 16, 2021: The Treasury and the IRS published a notice and request for comments on Revenue Procedure 2003-33, which provides qualifying taxpayers with an extension of time—pursuant to Treasury Regulations Section 301.9100-3—to file an election described in IRC § 338(a) or IRC § 338(h)(10) to treat the purchase of a corporation’s stock as an asset acquisition. Written comments should be received on or before November 15, 2021.

September 17, 2021: The Treasury and the IRS published a notice and request for comments on forms used by business entity taxpayers, including Forms 1065, 1066, 1120, 1120-C, 1120-F, 1120-H, 1120-ND, 1120-S, [...]

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Weekly IRS Roundup May 17 – May 21, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 17, 2021 – May 21, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 17, 2021: The IRS issued Revenue Ruling 2021-9, providing various prescribed interest rates for federal income tax purposes for June 2021.

May 17, 2021: The IRS issued Revenue Procedure 2021-24, providing procedures for individuals who are not required to file federal income tax returns to receive advance Child Tax Credit payments and third-round Economic Impact Payments under the American Rescue Plan Act of 2021 (ARPA), as well as 2020 recovery rebate credits under earlier coronavirus-related legislation.

May 17, 2021: The IRS issued a news release, reminding taxpayers that May 17 is the filing deadline for most individual income tax returns and summarizing various e-filing and extension options.

May 17, 2021: The IRS issued a news release, announcing that the first monthly payments under the Child Tax Credit, as expanded by ARPA, will be made to eligible families on July 15, 2021.

May 18, 2021: The IRS issued Notice 2021-31 and an accompanying news release, providing guidance on the temporary premium assistance for Consolidated Omnibus Budget Reconciliation Act (COBRA) health insurance benefits, and the associated COBRA premium assistance credit, enacted by ARPA.

May 19, 2021: The IRS issued Notice 2021-33, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

May 19, 2021: The IRS issued a news release, summarizing various tax benefits available to individuals experiencing homelessness, the rural poor and other underserved groups and urging employers and community groups to spread information about such benefits and assist such individuals in filing 2020 tax returns.

May 20, 2021: The IRS issued a news release, urging taxpayers who missed the recent May 17 tax-filing deadline to file their tax returns as soon as possible to obtain refunds or limit penalties and interest.

May 21, 2021: The IRS issued Notice 2021-32, providing the 2021 inflation adjustment factors and reference prices for the renewable electricity production credit, refined coal production credit and Indian coal production credit under section 45 of the Code.

May 21, 2021: The IRS issued an Action on Decision, announcing that it would not acquiesce to Machacek v. Comm’r, 906 F.3d 429 (6th Cir. 2018), which held that the economic benefits of a compensatory split-dollar life insurance arrangement may be treated as a distribution under section 301 of the Code.

May 21, 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 Le Chen in our Washington, DC, office for this week’s roundup.




Weekly IRS Roundup May 10 – May 14, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 10, 2021 – May 14, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 10, 2021: The IRS issued Revenue Procedure 2021-25, announcing various inflation-adjusted amounts relevant to health savings accounts (HSAs) for calendar year 2022.

May 10, 2021: The IRS issued Notice 2021-26 and an accompanying news release, clarifying that unused amounts from dependent care assistance programs for 2020 that are carried over to 2021 or 2022 (pursuant to coronavirus-related legislation) remain excludible from gross income for those later years.

May 11, 2021: The IRS issued Revenue Procedure 2021-26, providing procedures under section 446(e) of the Code for certain foreign corporations to obtain automatic IRS consent to change to the alternative depreciation system of accounting under section 168(g) of the Code.

May 11, 2021: The IRS issued a news release, providing an overview of certain key tax provisions in the American Rescue Plan Act of 2021 (ARPA), including provisions retroactive to the 2020 taxable year.

May 12, 2021: The IRS issued a news release, announcing a ninth round of Economic Impact Payments consisting of nearly one million payments worth more than $1.8 billion, bringing the total amount of disbursements under ARPA to approximately 165 million payments worth approximately $388 billion.

May 13, 2021: The IRS issued a news release, announcing that, in response to recent disruptions to the fuel supply chain, it is waiving penalties for failure to make semi-monthly deposits of excise tax on the sale of dyed diesel fuel for highway use. The relief is retroactive to May 7, 2021, and is in effect through May 21, 2021, and the IRS stated that it is closely monitoring the situation and will provide additional relief as needed.

May 13, 2021: The IRS issued a news release, extending the deadline to apply for 2022 membership on the Taxpayer Advocacy Panel, a federal advisory committee formed to identify taxpayer concerns and make recommendations for improving IRS service, through June 1, 2021.

May 14, 2021: The IRS issued Announcement 2021-10, clarifying that the boundaries of qualified opportunity zones created under the Tax Cuts and Jobs Act are unaffected by the results of the 2020 decennial census.

May 14, 2021: The IRS issued a news release, announcing that victims of storms and tornadoes that occurred in Tennessee in late March and early April would have until August 2, 2021, to file individual and business tax returns and make tax payments.

May 14, 2021: The IRS issued a news release, announcing that it has commenced issuing refunds to taxpayers who paid taxes on 2020 unemployment compensation, compensation that ARPA later excluded from 2020 taxable income.

May 14, [...]

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Weekly IRS Roundup January 7 – 11, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 7 – 11, 2019. Tax news is very limited because of the government shutdown:

January 7, 2019: The IRS issued a news release confirming that, despite the partial federal government shutdown, it will process tax returns beginning January 28, 2019, and provide refunds to taxpayers as scheduled.

January 7, 2019: The IRS released the final 2018 version of Form 8996, dealing with certification as a qualified opportunity fund under section 1400Z-2 of the Code, enacted in the Tax Cuts and Jobs Act.

January 7, 2019: The IRS issued an announcement cancelling a public hearing—originally scheduled for January 10, 2019—on proposed regulations concerning qualified opportunity funds under section 1400Z-2 of the Code, in light of the partial federal government shutdown.

January 7, 2019: The IRS released final instructions for Form 8992, dealing with the calculation of global intangible low-taxed income under section 951A of the Code, enacted in the Tax Cuts and Jobs Act.

January 8, 2019: The IRS released the final 2018 version of Form 8992, dealing with the calculation of global intangible low-taxed income under section 951A of the Code, enacted in the Tax Cuts and Jobs Act.

January 11, 2019: The IRS issued a news release announcing the start of the IRS Free File program for this filing season and detailing new consumer protections that have been added to the program.

Special thanks to Le Chen in our DC office for this week’s roundup.




Tax Court Addresses Statute of Limitations Issues in Rafizadeh v. Commissioner

Andrew Roberson and Elizabeth Chao recently wrote an article for Law360 entitled, “A Recent Tax Court View Of Statute Of Limitations Provisions.” The article discusses the Tax Court’s recent opinion in Rafizadeh v. Commissioner on statute of limitations for amounts reportable under Internal Revenue Code Section 6038D.

Read the full coverage on Law360 here.




Former Tax Court Judge Diane L. Kroupa Sentenced in Connection with Tax Evasion Matter

We have previously blogged on the criminal tax proceedings related to former US Tax Court Judge Kroupa (see here and here). In October 2016, Judge Kroupa pleaded guilty to multiple tax criminal charges related to her tax returns and interactions with the Internal Revenue Service. Based on sentencing guidelines, the recommended sentence was between 30‒37 months. Judge Kroupa and the government submitted filings on the appropriate sentence, in which Judge Kroupa provided detailed reasons why she believed the court should impose a sentence of 20 months imprisonment. These filings can be found here and here. According to a report in today’s BNA Daily Tax Report, the court sentenced Judge Kroupa to 34 months in prison and ordered her to pay $457,000 in restitution, which is owed jointly with her former husband. She was also sentenced to three years of supervised release. Judge Kroupa’s former husband was sentenced to 24 months in prison and one year of supervised release.




IRS Opposes Granting of Certiorari in Cases Addressing Definition of Return

Two petitions for certiorari pending before the Supreme Court of the United States ask the Court to resolve the question of whether a tax return filed after an assessment by the Internal Revenue Service (IRS) is a “return” for purposes of the Bankruptcy Code (BC). The answer to this question will determine whether a bankrupt taxpayer’s tax debts can be discharged or are permanently barred from discharge. According to these petitions, the courts of appeal are divided as to the answer.

BC § 523(a) generally allows a debtor to discharge unsecured debt, except for, inter alia, tax debts of debtors who: (1) failed to file tax returns; (2) filed fraudulent tax returns; or (3) filed late tax returns, where a bankruptcy petition is filed within two years of the date the late return was filed. See BC § 523(a)(1)(B)(i), (B)(ii), (C).

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