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Weekly IRS Roundup August 24 – August 28, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. August 24 2020: The IRS published a memorandum concerning guidance to the field on the criteria that should be applied in considering if a request for designation for litigation should be made to the Office of Chief Counsel. The memorandum also provides interim guidance on the requirements of Section 1001 of the Taxpayer First Act (TFA) with respect to the limitation on designation of cases as not eligible for referral to the IRS Independent Office of Appeals. August 25, 2020: The IRS published a Summer 2020 Statistics of Income Bulletin. The Summer 2020 Bulletin focuses individual income tax shares, 2017; foreign recipients of US income, calendar year 2017; effects of post-filing adjustments on...

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Weekly IRS Roundup July 20 – July 24, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 20, 2020 – July 24, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. July 20, 2020: The IRS published a news release on after-tax-day tips for taxpayers who missed the July 15, 2020, tax deadline and did not request an extension. The tips include advice on obtaining a refund and on reducing penalties and interest. July 20, 2020: The IRS released public comments on the 2020-21 Priority Guidance Plan in response to Notice 2020-47, which invited the public to submit recommendations for items to be included on the 2020-2021 Priority Guidance Plan. The US Department of the Treasury and the IRS use the Priority Guidance Plan each year to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices and other...

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Weekly IRS Roundup January 6 – January 10, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6 – January 10, 2020. January 6, 2020: The IRS issued a News Release confirming that the 2019 tax filing season will be open for individual filers—and that the IRS will begin accepting and processing 2019 tax year returns—on January 27, 2020. The IRS explained that though taxpayers may prepare returns through the IRS’ Free File program before that date, the IRS will begin processing these returns when their systems open on January 27. The IRS also noted that the deadline to file 2019 tax returns and to pay any tax owed is April 15, 2020. January 8, 2020: The Acting National Taxpayer Advocate released her 2019 Annual Report to Congress, highlighting challenges such as the implementation of the Taxpayer First Act, inadequate taxpayer service and limited funding of the agency. Also released was the third edition of the National...

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Taxpayer First Act: Changes to the IRS Appeals Process

The enactment of the Taxpayer First Act, H.R. 3151 (116th Cong.) (TFA) brings with it several changes to the procedures and operations of the Internal Revenue Service (IRS). The TFA touches on the following subjects: Establishing the IRS Independent Office of Appeals Improving customer service Changes to enforcement Modernization of the Office of the National Taxpayer Advocate and the IRS Cybersecurity and identity protection, technological changes, and expanded use of electronic systems IRS hiring and disclosure changes Provisions relating to exempt organizations Changes to the penalty for failure to file Determination of budgetary effects Other miscellaneous provisions This post does not discuss each subject, but rather focuses on changes to the IRS Appeals process. The TFA establishes a new “Internal Revenue Service Independent Office of Appeals” that is under the direction of the “Chief of Appeals.” The right of appeal is “generally available to all...

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Tax Reform Insight: Congress Offers a Glimmer of Hope for Taxpayers with Section 965 Transition Tax Overpayment

Recently proposed legislation would provide taxpayers who made an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through installment payments the ability to claim a refund or credit of any overpayment with respect to such amounts. If enacted, taxpayers would be able to claim a refund or credit on an overpayment with respect to their first installment payment under Code Section 965(h). On November 26, 2018, House Ways and Means Committee Chair Kevin Brady, R-Texas, introduced the Retirement, Savings and Other Tax Relief Act of 2018 and the Taxpayer First Act of 2018 (H.R. 88), which was subsequently revised on December 17, 2018 (the Bill). The Bill is a broad tax package that includes certain tax extenders, retirement savings proposals, Internal Revenue Service (IRS) improvement legislation and several technical corrections to the Tax Cuts and Jobs Act (P.L. 115-97). Included in the Bill is a provision...

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