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IRS roundup: March 9 – March 25, 2026

by Kai M. Fenty, Matthew J. Blaney and Edward L. Froelich | Mar 26, 2026 | Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts

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 for November 25 – December 13, 2024

by Kevin Spencer, Evan Walters and Samuel F. Hamer | Dec 17, 2024 | IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2024 – December 13, 2024.

November 25, 2024: The IRS released Treasury Decision 10011, which modifies the regulations governing the sale of a taxpayer’s property that the IRS seizes by levy. The modified regulations allow the IRS to maximize sale proceeds for the benefit of the taxpayer and the public fisc. Effective November 5, 2024, these regulations affect all sales of property the IRS seizes by levy.

November 26, 2024: The IRS issued Notice 2024-85, announcing revisions to transition relief for third-party settlement organizations under Internal Revenue Code (Code) § 6050W, also known as “payment apps” and “online marketplaces.” Under this guidance, payors will be required to report transactions when the amount of total payments is more than $5,000 in 2024, more than $2,500 in 2025, and more than $600 in calendar year 2026 and after.

November 26, 2024: The IRS issued Announcement 2024-40 in which it confirmed that amounts paid or incurred by a taxpayer for the construction, expansion, or modernization of advanced manufacturing facilities pursuant to an agreement entered into with the US Department of Commerce under 15 U.S.C. § 4652(a)(6)(C) (the CHIPS Act of 2022) will not fail, solely by reason of such agreement, to constitute a “qualified investment” for purposes of determining the amount of any advanced manufacturing investment credit under Code § 48D.

December 2, 2024: The IRS released Internal Revenue Bulletin 2024-49, which includes the following:

Revenue Ruling 2024-25, which provides the interest rates for overpayments and underpayments of tax for the calendar quarter beginning January 1, 2025.

Revenue Ruling 2024-26, which provides the December 2024 applicable federal rates for purposes of Code § 1274(d) and relates to the determination of issue price in the case of certain instruments issued for property.

Notice 2024-81, which provides an update for weighted average interest rates, yield curves, and segment rates.

Notice 2024-83, which provides an update to the fee on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans to help fund the Patient-Centered Outcomes Research Trust Fund. This update is effective for plan years ending on or after October 1, 2024, and before October 1, 2025.

December 2, 2024: The IRS issued proposed regulations under Code § 959 regarding companies’ previously taxed earnings and profits (PTEP). These proposed regulations are the first in a series of guidance on PTEP rules. This first tranche of guidance includes a framework on which to build rules on mergers and acquisitions, along with provisions addressing basis adjustments under Code § 961 and foreign-currency gains and losses.

December 2, 2024: The IRS announced that December 2 marked the beginning of the 9th annual National Tax Security Awareness Week. The IRS warned of holiday scams and [...]

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Weekly IRS Roundup May 20 – May 24, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | May 31, 2024 | IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024.

May 20, 2024: The IRS released Internal Revenue Bulletin 2024-21, which includes the following:

Treasury Decision 9992, which includes final regulations on the standards under which a qualified investment entity, such as a real estate investment entity, would be “domestically controlled” for purposes of 897(h)(2) of the Internal Revenue Code (Code), effective as of April 25, 2024. The final regulations are generally consistent with the proposed regulations previously issued on December 29, 2022, and include a 10-year transition rule for certain existing structures.

Notice 2024-37, which provides guidance on the availability of the Sustainable Aviation Fuel (SAF) Tax Credit found in Code 40B as both an income tax credit and an excise tax credit under Code §§ 6426 and 6427. The notice also provides additional safe harbors under which the SAF’s life cycle greenhouse gas emissions reduction percentage can be calculated.

Revenue Procedure 2024-24, which provides procedures for requesting private letter rulings for transactions intended to qualify under Code 355 as tax-free spin-offs. The guidance was accompanied by Notice 2024-38, which requests taxpayer comments with respect to all provisions in the guidance.

Announcement 2024-18, which lists disciplinary sanctions for certain professionals, including lawyers, certified public accountants and appraisers, for violating the regulations governing practice before the IRS set out in Circular 230.

Announcement 2024-21, which revokes the Code § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

Supplemental guidance accompanying the proposed regulations from December 26, 2023, relating to the Code 45V tax credit for the production of clean hydrogen and the Code § 48(a)(15) election to treat clean hydrogen production facilities as energy property.

May 20, 2024: The IRS was recognized for its financial management and performance reporting in its 2023 Agency Financial Report.

May 21, 2024: The IRS provided an overview of tax deductions, housing allowances and other tax benefits that homeowners can use to save money and offset related costs.

May 22, 2024: The IRS provided year-round tax planning pointers to help taxpayers stay organized and facilitate their tax planning. Among other things, the IRS suggests creating a system to keep tax records together; checking withholdings using the IRS withholding estimator; and notifying USPS, employers and the IRS of any address or name changes.

May 22, 2024: The IRS announced that the Qualifying Advanced Energy Project Credit Program Applicant Portal (Code § 48C Portal), which provides a tax credit for investments in advanced energy projects, is open for concept paper submissions. Submissions [...]

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IRS roundup: March 9 – March 25, 2026

IRS Roundup for November 25 – December 13, 2024

Weekly IRS Roundup May 20 – May 24, 2024

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