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IRS roundup: July 12 – July 29, 2025

by , , , and | Aug 15, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025.

IRS guidance 

July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for federal income tax purposes for August 2025, including but not limited to:

  • Short-, mid-, and long-term applicable federal rates for August 2025 for purposes of Internal Revenue Code (Code) Section 1274(d).
  • Short-, mid-, and long-term adjusted applicable federal rates for August 2025 for purposes of Code Section 1288(b).
  • The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code Section 382(f).
  • The appropriate percentages for determining the low-income housing credit described in Section 42(b)(1) for buildings placed in service during the current month.
  • The federal rate for determining the present value of an annuity, an interest for life, a term of years, a remainder, or a reversionary interest for purposes of Code Section 7520.

July 15, 2025: The IRS issued Notice 2025-39, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Code Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code Section 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code Section 431(c)(6)(E)(ii)(I).

July 16, 2025: The IRS issued Revenue Ruling 2025-15, clarifying certain withholding and reporting requirements with respect to uncashed retirement plan distribution checks. The IRS held that no adjustment or refund is available under Sections 6413 and 6414 with respect to amounts withheld and remitted when more than the correct amount of tax was not withheld or paid.

July 16, 2025: The IRS issued Notice 2025-40, providing updated static mortality tables for defined benefit pension plans under Code Section 430(h)(3)(A) and Section 303(h)(3)(A) of the Employee Retirement Income Security Act of 1974 (ERISA). These updated static mortality tables apply for purposes of calculating the funding target and other items for valuation dates occurring during the 2026 calendar year.

The notice also includes a modified unisex version of the mortality tables for determining the minimum present value under ERISA Sections 417(e)(3) and 205(g)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2026 calendar year. 

July 21, 2025: The IRS issued Notice 2025-36, identifying and making obsolete 83 Internal Revenue Bulletin guidance documents. The notice cites Executive Order 14192, Unleashing Prosperity Through Deregulation, which directed agencies to identify regulations to be repealed and other guidance that are appropriate for withdrawal. The 83 obsolete regulations span multiple contexts and Code sections.

July 21, 2025: The IRS issued Notice 2025-37, which includes the inflation adjustment factors and applicable amounts for calendar year 2025 for the zero-emission nuclear power production credit under Code Section 45U. It [...]

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IRS roundup: June 3 – 17, 2025

by , , , and | Jun 26, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 3, 2025 – June 17, 2025.

Commissioner update

June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative for Missouri’s 7th congressional district from 2011 to 2023. His term will run through November 12, 2027.

IRS guidance

June 12, 2025: The IRS has announced that it is experiencing a delay in processing electronic payments and that some taxpayers are receiving notices indicating a balance due even though payments were timely made.

Taxpayers who receive a balance due notice but electronically paid the tax they owed in full and on time do not need to respond. The IRS has said that any associated penalties and interest will be automatically adjusted once the payment(s) are applied correctly.

June 12, 2025: The IRS released Tax Tip 2025-39, reminding businesses about the Childcare Tax Credit. Taxpayers may receive a credit of up to $150,000 per year to offset 10% of qualified childcare resource and referral costs and 25% of qualified childcare facility costs.

To be eligible for the credit, an employer must have paid or incurred qualified childcare costs during the tax year to provide childcare services to employees. Employers should complete Form 8882, Credit for Employer-Provided Childcare Facilities and Services, to claim the credit. The credit is subject to the carryback and carryover rules for business credits.

June 12, 2025: The IRS issued Notice 2025-33, extending for an additional year the transitional relief provided in Sections 3.01, 3.02, and 3.06 of Notice 2024-59. Notice 2025-33 provides transitional relief from penalties with respect to certain information reporting obligations under Section 6045 and provides transitional relief from the liability for the payment of backup withholding tax required to be withheld under Section 3406 and its accompanying regulators.

This notice also provides transitional relief from penalties for brokers who fail to pay that tax with respect to certain sales of digital assets required to be reported under Section 6045, as well as a digital asset sale relief for certain customers that have not been previously classified by the broker as US persons.

June 13, 2025: The IRS issued Notice 2025-35, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code Section 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code Section 431(c)(6)(E)(ii)(I).

June 17, 2025: The IRS issued Revenue Ruling 2025-13, providing prescribed rates for federal income tax purposes for July 2025, including but not limited to:



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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 17 – March 14, 2025

by , , and | Mar 14, 2025 |

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025.

Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition in recent weeks and issued significantly less guidance than normal. We did not publish the IRS Roundup regularly during these weeks as we awaited new guidance from the agency.

February 19, 2025: The IRS issued Revenue Ruling 2025-6, providing the March 2025 short-, mid-, and long-term applicable federal rates for purposes of Section 1274(d) of the Internal Revenue Code (Code), as well as other provisions.

February 21, 2025: The IRS issued Notice 2025-15, providing guidance on the alternative method for furnishing health insurance coverage statements to individuals, as required by Code Sections 6055 and 6056. This alternative method allows entities to post a clear and conspicuous notice on their websites, informing individuals that they can request a copy of their health coverage statement. This notice must be posted by the due date for furnishing the statements and retained through October 15, 2026. The guidance applies to statements for calendar years after 2023.

March 5, 2025: The IRS issued Revenue Procedure 2025-17, providing guidance for individuals who failed to meet the eligibility requirements of Code Section 911(d)(1) (foreign earned income exclusion) for 2024 because of adverse conditions in certain foreign countries. The revenue procedure lists specific countries, including Ukraine, Iraq, Haiti, and Bangladesh, where war, civil unrest, or similar conditions precluded normal business conduct. Individuals who left these countries on or after specified dates in 2024 may still qualify for the foreign earned income exclusion if they can demonstrate that they would have met the eligibility requirements but for these adverse conditions.

March 5, 2025: The IRS issued Notice 2025-16, providing adjustments to the limitation on housing expenses for 2025 under Code Section 911. These adjustments account for geographic differences in housing costs relative to those in the United States. The notice includes a detailed table listing the adjusted housing expense limitations for locations worldwide. It also allows taxpayers to apply the 2025 adjusted limitations to their 2024 taxable year if the new limits are higher.

March 6, 2025: The IRS issued Revenue Ruling 2025-7, providing interest rates for tax overpayments and underpayments for the second quarter of 2025 in accordance with Code Section 6621.

March 11, 2025: The IRS issued Notice 2025-17, providing updates on the corporate bond monthly yield curve, spot segment rates, and 24-month average segment rates used under Code Sections 417(e)(3) and 430(h)(2). The notice includes the interest rate on 30-year Treasury securities and the 30-year Treasury weighted average rate for plan years beginning before 2008. It also specifies the minimum funding requirements for single-employer plans, the methodology for determining monthly corporate bond yield curves, and the adjusted 24-month average segment rates for March 2025. Additionally, the notice outlines the permissible range of rates for calculating current liability for multiemployer plans.



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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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Weekly IRS Roundup June 17 – June 21, 2024

by , and | Jun 27, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024.

June 17, 2024: The IRS released Internal Revenue Bulletin 2024-25, which includes the following:

  • Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.
  • Treasury Decision 9993, which provides final regulations on the election under Internal Revenue Code (Code) 6418 to transfer eligible energy credits, effective July 1, 2024.
  • Treasury Decision 9997, which reduces the cost of applying for or renewing a preparer tax identification number from $21 to $11.
  • Proposed Regulations, which would remove the “associated property rule” and related rules from the regulations on interest capitalization requirements for improvements to “designated property” under Code 263A(f) and clarify the definition of “improvement” in the existing regulations.

June 17, 2024: The IRS announced the establishment of a new dedicated group within the Office of Chief Counsel that will focus on developing guidance for partnerships, specifically with respect to the use of “basis shifting” transactions by related-party partnerships.

June 17, 2024: The IRS released guidance intended to target certain transactions that use the basis adjustment provisions in Code §§ 734, 743, 754 and 755 to shift basis to depreciable property through partnership transactions. This guidance includes:

  • Revenue Ruling 2024-14, which identifies three types of basis shifting transactions involving related parties that, according to the IRS, should be disallowed for lack of economic substance.
  • Notice 2024-54, which announces the IRS’s intent to propose regulations under Code §§ 732, 734, 743 and 755 that, if finalized, are intended to take effect on or after June 17, 2024. The regulations would identify several types of “covered transactions” in which basis step-ups resulting from partnership transactions would be disallowed. Unlike Revenue Ruling 2024-14, these regulations would not depend on a covered transaction lacking economic substance.
  • Proposed Regulation § 1.6011-18, which would identify certain partnership basis shifting transactions as “transactions of interest,” which generally must be disclosed to the IRS.

June 17, 2024: The IRS provided general tips for taxpayers benefiting from educational assistance programs under Code § 127 with respect to the treatment of certain educational expenses, qualified education loans and working condition fringe benefits.

June 17, 2024: The IRS released Notice 2024-53, which provides the 24-month average corporate bond segment rates for June 2024, yield curve and segment rates for single-employer plans and 30-year Treasury securities interest rates.

June 18, 2024: The IRS announced the release of final regulations for taxpayers who satisfy certain prevailing wage and apprenticeship (PWA) requirements regarding the construction, alteration or repair of certain clean energy facilities or properties, projects or equipment. Taxpayers who satisfy these PWA requirements are eligible for increased credit or deduction amounts for certain clean energy [...]

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Weekly IRS Roundup May 13 – May 17, 2024

by , and | May 24, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13, 2024 – May 17, 2024.

May 13, 2024: The IRS released Internal Revenue Bulletin 2024-20, which includes proposed regulations concerning the excise tax on stock buybacks under § 4501 of the Internal Revenue Code (Code). The proposed regulations are generally consistent with the guidance previously provided in Notice 2023-2. The proposed regulations also include guidance on reporting and payment of the Code § 4501 excise tax.

May 14, 2024: The IRS announced that, contrary to recent reports, there will be no changes to Native American tribes’ access to federal tax payment offsets through state arrangements.

May 14, 2024: The IRS reminded US citizens and resident aliens living abroad to file and pay their taxes.

May 14, 2024: The IRS warned taxpayers not to fall for inaccurate social media advice and tax scams centered around the Fuel Tax Credit, the Sick and Family Leave Credit and household employment taxes that led taxpayers to file inflated refund claims during the 2023 tax season.

May 14, 2024: The IRS released census tract geographic identifiers that are eligible for Code § 30C using 2015 and 2020 delineations of census tract boundaries, which can be accessed at Appendix A and Appendix B, respectively.

May 15, 2024: The IRS reminded businesses to check their tax returns for signs of incorrect Employee Retention Credit (ERC) claims and listed signs that an ERC claim could be incorrect.

May 15, 2024: The IRS released Notice 2024-42, which specifies updated static mortality tables for defined benefit pension plans under Employee Retirement Income Security Act of 1974 (ERISA) provisions for valuation dates occurring during the 2025 calendar year. The notice also includes a modified unisex version of the mortality tables for determining minimum present values under ERISA for distributions with annuity starting dates that occur during stability periods beginning in the 2025 calendar year.

May 15, 2024: The IRS released Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.

May 15, 2024: The IRS released Notice 2024-40, which provides the 24-month average corporate bond segment rates for May 2024, the yield curve and segment rates for single-employer plans and the 30-year Treasury securities interest rates.

May 16, 2024: The IRS released Notice 2024-41, which modifies Section 3.04 of Notice 2023-38 by revising the contents of the “Applicable Projects” list. The notice also provides a safe harbor under which taxpayers may elect to qualify for the domestic content bonus credit. Learn more here.

May 16, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Ohio that [...]

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Weekly IRS Roundup April 29 – May 3, 2024

by , and | May 7, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024.

April 29, 2024: The IRS released Internal Revenue Bulletin 2024-18, which includes the following:

  • Notice 2024-33, which provides a limited waiver of the addition to tax under Section 6655 of the Internal Revenue Code (Code) to the extent the addition to tax would be attributable to an underpayment of estimated corporate alternative minimum tax under Section 55 due April 15, 2024.
  • Notice 2024-34, which provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under Section 417(e)(3) of the Code, the 24-month average segment rates under Section 430(h)(2), the interest rate on 30-year Treasury securities under Section 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008, and the 30-year Treasury weighted average rate under Section 431(c)(6)(E)(ii)(I).

April 29, 2024: The IRS issued Notice 2024-36, which provides guidance on the procedures for allocating credits under Section 48C and announces a second round of credits under Section 48C(e) for participation in the Qualifying Advanced Energy Project Credit program.

April 29, 2024: The IRS reminded small businesses to take advantage of the many tax resources available to them through the Small Business and Self-Employed Tax Center on IRS.gov.

April 30, 2024: The IRS announced that it is accepting applications for Tax Counseling for the Elderly and Volunteer Income Tax Assistance grants, which allows eligible organizations to apply for annual funding to provide free federal tax return preparation assistance for up to three years.

April 30, 2024: The IRS issued Notice 2024-37, which provides additional guidance and safe harbors regarding sustainable aviation fuel credits under Sections 40B and 6426(k) of the Code.

May 1, 2024: The IRS warned taxpayers and tax professionals about common scams and schemes, including online account help from third-party scammers, phishing, unscrupulous tax return preparers, offer in compromise mills and employee retention credit scams.

May 1, 2024: The IRS encouraged entrepreneurs to put data security safeguards in place to protect their financial, personal and employee information from scams and cybercriminals.

May 1, 2024: The IRS reminded taxpayers that it provides relief when an emergency measures declaration is issued, supplementing governmental efforts to provide emergency services. The IRS also provides relief when a major disaster declaration offering “individual assistance” is issued, which allows individuals and households to apply to the Federal Emergency Management Agency for financial and direct services.

May 1, 2024: The IRS issued Revenue Procedure 2024-24, which outlines procedures for requesting private letter rulings involving “spin-off” transactions subject to Section 355. Notice 2024-38, issued in conjunction with Revenue Procedure 2024-24, requests feedback on these procedures.

May 1, 2024: The IRS reminded taxpayers to [...]

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Weekly IRS Roundup April 8 – April 12, 2024

by , and | Apr 15, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024.

April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15, which includes the following:

  • Announcement 2024-15, which revokes the § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under § 170(b)(1)(A) of the Internal Revenue Code (Code).
  • Notice 2024-31, which provides adjustments to the limitation on housing expenses for purposes of Code Section 911 for specific locations for 2024.
  • Revenue Procedure 2024-17, which provides a waiver under Code Section 911(d)(4) concerning time requirements for individuals who must leave a foreign country because of war, civil unrest or similar adverse conditions and are electing to exclude their foreign earned income. The revenue procedure also adds Ukraine, Belarus, Sudan, Haiti, Niger and Iraq to the list of waiver countries for tax year 2023 for which the minimum time requirements are waived.
  • Revenue Procedure 2024-18, which supplements Revenue Procedure 2023-32 by publishing amounts of unused housing credit carryovers allocated to qualified states under Code Section 42(h)(3)(D) for calendar year 2023 (in addition to those amounts published in Revenue Procedure 2023-32).
  • Final regulations, which describe rules for the elective payment of Inflation Reduction Act of 2022 tax credit amounts in a taxable year, including definitions and special rules applicable to partnerships and S corporations and regarding repayment of excessive payments. The regulations also describe rules related to a required IRS pre-filing registration process.
  • Final regulations, which describe rules for the elective payment of the advanced manufacturing investment credit under the Creating Helpful Incentives to Produce Semiconductors Act of 2022, including special rules applicable to partnerships and S corporations, repayment of excessive payments, and basis reduction and recapture. The regulations also describe rules related to a required IRS pre-filing registration process.

April 8, 2024: The IRS warned taxpayers about bad tax information on social media that can potentially lead to identity theft and tax problems.

April 9, 2024: The IRS warned tax professionals and businesses to remain vigilant and protect themselves against a continuing barrage of email spearfishing attempts, especially one particular type known as “new client” scams where identity thieves pose as potential clients using fake emails in hopes of stealing valuable information.

April 9, 2024: The IRS reminded taxpayers that its Direct File pilot is open to eligible taxpayers in 12 pilot states and allows the filing of 2023 federal tax returns online for free and directly with the IRS.

April 9, 2024: The IRS released proposed regulations that would implement the statutory netting rule, which reduces the aggregate fair market value of stock repurchased by a taxpayer during a certain taxable year. Additionally, [...]

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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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