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Weekly IRS Roundup May 13 – May 17, 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

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

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

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 March 13 – March 17, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023.

March 13, 2023: The IRS released Internal Revenue Bulletin 2023-11, which highlights the following:

  • Notice 2023-21: This notice postpones the beginning of the lookback periods under Section 6511 for certain taxpayers to file a claim for refund. Affected taxpayers include those who had tax returns due from April 15, 2020 to July 15, 2020, or from April 15, 2021 to May 17, 2021, and due to the COVID-19 pandemic, those due dates were postponed by Notice 2020-23 or Notice 2021-21 to July 15, 2020 or May 17, 2021, respectively.
  • Treasury Decision 9972: These final regulations amend the rules for filing certain returns and statements electronically to reflect changes made by the Taxpayer First Act of 2019 and to promote electronic filing.
  • Notice 2023-19: This notice provides guidance on the corporate bond monthly yield curve, corresponding spot segment rates and the 24-month average segment rates for February 2023. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.
  • REG 122286-18: These proposed regulations provide rules relating to the use of forfeitures in qualified retirement plans, including a deadline for the use of forfeitures in defined contribution plans, and clarify that forfeitures arising in any defined contribution plan may be used for one or more of the following purposes, as specified in the plan, to (1) pay plan administrative expenses, (2) reduce employer contributions under the plan or (3) increase benefits in other participants’ accounts in accordance with plan terms.
  • Action on Decision 2023-2: The IRS announced nonacquiescence to the US Tax Court’s decision in Complex Media, Inc. v. Commissioner, T.C. Memo. 2021-14, that the parties’ failure to report transactions fully or consistently should not be a major factor in a decision of whether to allow a taxpayer to disavow the form of its transactions and to the standard the Court applied to allow a petitioner to disavow its form. The IRS also announced nonacquiescence to the court’s determination that the fair market value of a “Deferred Payment Right” for purposes of Section 351(b)(1) is not equal to its issue price.
  • Treasury Decision 9973: This document contains final regulations that treat members of a consolidated group as a single US shareholder in certain cases for purposes of Section 951(a)(2)(B). The final regulations affect consolidated groups that own stock of foreign corporations.

March 13, 2023: The IRS announced that Danny Werfel began work as the 50th Commissioner of the IRS. Werfel was confirmed by the US Senate on March 9, 2023, and his term will run through November 12, 2027. You can read more about his confirmation
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Weekly IRS Roundup December 9 – 13, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019.

December 10, 2019: The IRS issued a notice providing that the requirement to report partners’ shares of partnership capital on the tax basis method will not be effective for 2019 for partnership taxable years beginning in calendar 2019. Instead, the requirements will be effective beginning in 2020 (for partnership taxable years that begin on or after January 1, 2020). The notice also defines a partner’s share of “net unrecognized Section 704(c) gain or loss” for purposes of partnership reporting.

December 10, 2019: The Joint Committee on Taxation released a report detailing proposed provisions of the “Restoring Tax Fairness for States and Localities Act.” The bill would increase the maximum state and local tax deduction that married couples can claim in 2019 and would eliminate the limitations on the maximum state and local tax deduction in 2020 and 2021. The bill would also increase the top marginal individual income tax rate under temporary rules.

December 11, 2019: The IRS issued a notice providing guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under section 417(e)(3), and the 24-month average segment rates under section 430(h)(2). The notice also provides guidance regarding both the interest rate on 30-year Treasury securities under section 417(e)(3) as well as the 30-year Treasury weighted average rate under section 431(c)(6).

December 13, 2019: The IRS issued proposed regulations that provide amendments to regulations under sections 162, 164 and 170 of the IRC. The proposed regulations reflect current law regarding the application of section 162 to a taxpayer that makes a payment or transfer to an entity described in section 170(c) for a business purpose; the regulations also provide safe harbors under section 162 to provide certainty for such payments. The regulations also provide a safe harbor under section 164 for payments made to an entity described in section 170(c) by individuals who itemize deductions and receive or expect to receive a state or local tax credit in return. The proposed regulations are scheduled to be published in the Federal Register on December 17, 2019. Public comments regarding the contemplated rules must be received by January 31, 2020.

December 13, 2019: The IRS released a revenue procedure clarifying that all plan amendments that both relate to a plan’s hardship distribution provisions and that are effective no later than January 1, 2020, shall be treated as integral to the required amendments under newly-updated sections 401(k) and 401(m). The revenue procedure also extended the deadline for pre-approved plans to adopt an interim amendment relating to those regulations.

December 13, 2019: The IRS released a revenue ruling providing that the base period T-bill rate for the period ending September 30, 2019, is 2.32%. Section 995(f)(1) of the IRC provides that a shareholder of a domestic international sales corporation (a “DISC”) shall pay annual interest equal to [...]

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