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Weekly IRS Roundup April 17 – April 21, 2023

by | Apr 24, 2023 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023.

April 17, 2023: The IRS released Internal Revenue Bulletin 2023-16, which highlights the following:

  • Announcement 2023-10: This announcement was issued pursuant to the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the US Secretary of the Treasury to annually report advance pricing agreements and the Advance Pricing and Mutual Agreement Program (APMA Program). This year’s report describes the experience, structure and activities of the APMA Program during 2022.
  • REG-105954-22: This notice provides guidance related to Sections 4661, 4662, 4671 and 4672, collectively referred to as the Superfund chemical taxes. Section 4661(a) imposes an excise tax on the sale or use of “taxable chemicals” by manufacturers, producers or importers. Section 4671(a) imposes an excise tax on the sale or use of “taxable substances” by importers. The Superfund chemical taxes previously expired on December 31, 1995, but were reinstated with certain modifications, effective July 1, 2022, by Section 80201 of the Infrastructure Investment and Jobs Act.
  • Notice 2023-31: This notice announces that when proposed regulations under Section 903 (REG-112096-22) are finalized, the US Department of the Treasury and the IRS intend to extend the transition period for the single-country exception’s documentation requirement from May 17, 2023, to 180 days after the final regulations are filed. The single-country exception provides relief from the source-based attribution requirement under Section 903 for foreign withholding taxes on royalties paid for the use of intellectual property within the withholding jurisdiction.
  • REG-120080-22: This document contains proposed regulations regarding the clean vehicles credit under Section 30D. These proposed regulations will affect persons seeking to claim the credit and qualified manufacturers of clean vehicles. The IRS also issued a reminder that the proposed regulations went into effect on April 18.
  • Revenue Ruling 2023-2: This revenue ruling confirms that the basis adjustment under Section 1014 generally does not apply to the assets of an irrevocable grantor trust not included in the deceased grantor’s gross estate for federal estate tax purposes.

April 17, 2023: The IRS released Revenue Ruling 2023-9, which provides the applicable federal rates for federal income tax purposes for May 2023. The short-term federal interest rate is 4.30%, the mid-term rate will drop to 3.57% and the long-term rate will fall to 3.72%.

April 17, 2023: The IRS reminded taxpayers who need additional time to file their taxes that they can get an extension via IRS Free File.

April 17, 2023: The IRS released Tax Tip 2023-51, providing information to taxpayers regarding how to file a final federal tax return for someone who has died.

April 17, 2023: The IRS reminded last-minute tax [...]

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Weekly IRS Roundup April 10 – April 14, 2023

by | Apr 17, 2023 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 10, 2023 – April 14, 2023.

April 10, 2023: The IRS released Internal Revenue Bulletin 2023-15, which highlights the following:

  • Revenue Procedure 2023-20: This revenue procedure modifies the effective date of additions to the taxable substances or chemicals list under Section 4672(a). Specifically, this revenue procedure changes the date on which substances are added to the list for purposes of refund claims under Section 4662(e).
  • Notice 2023-27: This notice announces that the US Department of the Treasury and the IRS intend to issue guidance related to the tax treatment of certain non-fungible tokens (NFTs). The guidance requests comments on the treatment of NFTs as collectibles and describes how the IRS intends to determine whether an NFT is a collectible until further guidance is issued.
  • Notice 2023-28: This notice extends temporary relief regarding deposits of the excise tax imposed on certain chemicals under Section 4661 and the excise tax imposed on certain imported chemical substances under Section 4671 (collectively, Superfund chemical taxes). The extended relief is available in connection with deposits of the Superfund chemical taxes for semimonthly periods in the second, third and fourth calendar quarters of 2023.
  • REG-120653-22: These proposed regulations implement the advanced manufacturing investment credit, a new current-year business tax credit under Section 48D to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment within the United States. The regulations address the credit’s eligibility requirements, an election that eligible taxpayers may make to be treated as making a payment of tax (including an overpayment of tax) or for an eligible partnership or S corporation to receive an elective payment instead of claiming a credit, and a special 10-year credit recapture rule that applies if there is a significant transaction involving the material expansion of semiconductor manufacturing capacity in a foreign country of concern.
  • Revenue Ruling 2023-7: This revenue ruling provides the fringe benefits aircraft valuation formula. For purposes of Section 1.61-21(g) of the regulations, relating to the rule for valuing non-commercial flights on employer-provided aircrafts, the Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the first half of 2023 are as follows:

April 10, 2023: The IRS released Tax Tip 2023-47, providing guidance on when to file an amended income tax return.

April 10, 2023: The IRS and the Treasury issued Notice 2023-30, providing safe harbor deed language for extinguishment and boundary line adjustment clauses as required by the SECURE 2.0 Act of 2022. Section 605(d)(2) provides donors with the opportunity to amend certain conservation easement deeds to substitute the [...]

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Weekly IRS Roundup June 27 – July 1, 2022

by | Jul 6, 2022 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 27, 2022 – July 1, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

June 27, 2022: The IRS issued Bulletin 2022-26, announcing that it is revising the optional standard mileage rates for business, medical and moving expenses. This modification stems from increased fuel prices. The revised standard mileage rates are 62.5 cents per mile for business expenses and 22 cents per mile for medical and moving expenses.

June 27, 2022: The IRS issued Notice 2022-30, announcing that it intends to amend regulations under sections 59A and 6038A to defer the applicability date of certain provisions related to qualified derivative payments (QDPs) until 2025.

June 28, 2022: The IRS issued Rev. Proc. 2022-26, which provides the exclusive procedures for requesting a determination under § 4672(a)(2) of the Internal Revenue Code (Code) that a substance be added to or removed from the list of taxable substances.

June 28, 2022: The IRS proposed amendments to regulations under section 2053, which provide guidance on determining: (1) the amount deductible by an estate for funeral expenses, administration expenses and certain claims against the estate; (2) the deductibility of interest expenses accruing on tax and penalties owed by an estate and interest expenses accruing on certain loan obligations incurred by an estate; (3) the requirements for substantiating the value of a claim against an estate that is deductible; and (4) the deductibility of amounts paid under a decedent’s personal guarantee.

June 29, 2022: The Electronic Tax Administration Advisory Committee (ETAAC) released its annual report to US Congress. The featured recommendations include a focus on budget support for the IRS as well as enhancements to e-filing. The IRS issued a subsequent news release discussing the report.

June 29, 2022: The IRS issued Notice 2022-31, providing guidance on changes made by section 9707 of the American Rescue Plan Act of 2021 (ARPA) to the election of alternative minimum funding standards under section 430(m) of the Code for a defined benefit pension plan that is a community newspaper or any other plan that is sponsored by an eligible newspaper plan sponsor.

June 29, 2022: The IRS announced that beginning September 25, 2022, it will implement a new electronic fingerprinting process, which will require users to schedule an appointment with an IRS authorized vendor for fingerprinting. The deadline to mail in fingerprint cards (Form FD-258) to the IRS is August 15, 2022.

July 1, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Sarah Raben in our Chicago office for this week’s roundup.



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