TAX CONTROVERSY 360

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 November 18 – November 22, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Dec 2, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024.

November 18, 2024: The IRS released Internal Revenue Bulletin 2024-47, which includes the following:

Revenue Procedure 2024-41, which provides the unused housing credit carryover amounts allocated to qualified states under § 42(h)(3)(D) of the Internal Revenue Code (Code) for calendar year 2024.
Announcement 2024-37, which revokes the determination for specified organizations under Code § 501(c)(3) and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).
Proposed regulations, which ensure that non-grandfathered group health plans and insurance issuers provide an accessible exceptions process for preventive services, allowing coverage without cost sharing if deemed medically necessary by an individual’s provider. The rules also require coverage of certain over-the-counter contraceptive items without a prescription and without cost sharing.

November 18, 2024: The IRS released Revenue Ruling 2024-25, which establishes the interest rates for tax overpayments and underpayments for the calendar quarter beginning January 1, 2025, for corporations and individuals.

November 18, 2024: The IRS emphasized the importance of reporting tax-related fraud and protecting personal and financial information from scams and schemes and encouraged taxpayers to recognize red flags and utilize available IRS resources to report suspicious activities.

November 19, 2024: The IRS released proposed regulations and final regulations, which allow certain unincorporated organizations co-owning clean energy projects to opt out of partnerships and access refundable tax credits through elective pay under Code § 6417. This benefits unincorporated organizations and their members, including state and local governments and certain tax-exempt organizations, which previously could not utilize these credits because of little or no federal tax liability. The proposed regulations also provide the administrative requirements for unincorporated organizations opting out of partnership treatment.

November 22, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).

Weekly IRS Roundup November 11 – November 15, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Nov 27, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11, 2024 – November 15, 2024.

November 11, 2024: The IRS released Internal Revenue Bulletin 2024-46, including Revenue Procedure 2024-31, which outlines the requirements for manufacturers to be treated as “qualified manufacturers” under Section 25C(h) of the Internal Revenue Code. The guidance also specifies that energy-efficient home improvement credits won’t be allowed for items placed in service after December 31, 2024, unless the registration, product identification number assignment, labeling, and periodic reporting requirements are met.

November 13, 2024: The IRS released Notice 2024-81, which provides the 24-month average corporate bond segment rates for November 2024, the yield curve and segment rates for single-employer plans, and the 30-year Treasury securities interest rates.

November 13, 2024: The IRS reminded US Armed Forces members, veterans, and their families of special tax benefits and resources to help manage their unique tax situations, including tax-free combat pay, deadline extensions for those in combat zones, and free tax assistance via the military Volunteer Income Tax Assistance program.

November 14, 2024: The IRS reminded individual retirement arrangement owners aged 70½ and older that they can make up to $105,000 in tax-free charitable donations in 2024 through qualified charitable distributions (QCDs), an increase from the previous $100,000 limit. For those 73 or older, QCDs also count toward the year’s required minimum distribution.

November 15, 2024: The IRS released Revenue Ruling 2024-26, which provides the December 2024 applicable federal rates.

November 15, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).

Weekly IRS Roundup November 4 – November 8, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Nov 18, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4, 2024 – November 8, 2024.

November 4, 2024: The IRS released Internal Revenue Bulletin 2024-45, which includes the following:

Treasury Decision 10008, which provides guidance on federal income tax withholding under § 3405 of the Internal Revenue Code (Code) for periodic payments and nonperiodic distributions from employer-deferred compensation plans, individual retirement plans, and commercial annuities that are not eligible rollover distributions. Effective January 1, 2026, these regulations also cover payments and distributions made to payees outside the United States.
Revenue Ruling 2024-24, which provides the November 2024 applicable federal rates.
Notice 2024-74, which provides guidance on safe harbors for sustainable aviation fuel (SAF) credits under Code §§ 40B and 6426(k), as established by the Inflation Reduction Act of 2022, and instructs taxpayers to use the updated October 2024 40BSAF-GREET model for calculating emissions reductions for SAF credits.
Notice 2024-76, which provides the 24-month average corporate bond segment rates for October 2024, yield curve and segment rates for single-employer plans, and 30-year Treasury securities interest rates.
Notice 2024-77, which provides guidance on the treatment of inadvertent benefit overpayments under Code §§ 414(aa) and 402(c)(12) and outlines how these overpayments can be corrected and treated as eligible rollover distributions.
Revenue Procedure 2024-40, which provides the annual inflation adjustments for tax year 2025, affecting several tax provisions. Key changes include increases in the standard deduction, marginal tax rates, and various tax credits and exclusions.

November 7, 2024: The IRS released its 2024 financial report, which presents the IRS’ current financial position and resolves a long-standing deficiency in its information system controls.

November 7, 2024: The IRS reminded employees they can contribute up to $3,300 to a healthcare flexible spending arrangement in 2025 and use tax-free dollars for medical expenses not covered by other health plans, such as co-pays, deductibles, dental and vision care, and over-the-counter items.

November 7, 2024: The IRS warned taxpayers about scammers who set up fake charities to exploit generosity during natural disasters and reminded them to verify the legitimacy of charities using the Tax Exempt Organization Search Tool before making donations.

November 8, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup October 28 – November 1, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Nov 4, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28, 2024 – November 1, 2024.

October 28, 2024: The IRS released Internal Revenue Bulletin 2024-44, which includes the following:

Treasury Decision 9994, which provides guidance on § 367(d) of the Internal Revenue Code (Code) regarding the transfer of intangibles by US persons to foreign corporations. Effective January 1, 2024, the regulations turn off the application of § 367(d) when foreign corporations repatriate the intangibles to a qualified domestic person when certain reporting requirements are satisfied.
Notice 2024-71, which provides a safe harbor under Code § 213(d), treating amounts paid for condoms as medical care expenses eligible for reimbursement under various health plans. These amounts can also be paid or reimbursed, but if reimbursed, they are not deductible.
Notice 2024-75, which expands the list of preventive care benefits that high deductible health plans can provide without a deductible or with a lower deductible, including benefits for over-the-counter oral contraceptives and condoms, regardless of whether they are purchased with a prescription. The guidance is effective for plan years that began on or after December 30, 2022.
Revenue Procedure 2024-33, which updates the guidelines and general requirements for developing, printing, and approving substitute tax forms as detailed in Revenue Procedure 2023-28 to ensure submitted forms can be accepted as substitutes for official IRS forms.
Announcement 2024-36, which revokes the determination for specified organizations under Code § 501(c)(3) and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

October 28, 2024: The IRS reminded taxpayers to stay alert against online threats like identity theft and fraud. As National Cybersecurity Awareness Month concludes, the agency also offered tips, such as using strong passwords, enabling multifactor authentication, and avoiding phishing scams, to protect one’s personal information.

October 28, 2024: The IRS released Notice 2024-78, which extends the temporary relief provided in Notice 2023-11 for foreign financial institutions required to report US taxpayer identification numbers for certain preexisting accounts. This relief applies to eligible institutions under a Model 1 intergovernmental agreement for the 2025, 2026, and 2027 calendar years.

October 28, 2024: The IRS reminded employers that hiring individuals from specific groups can help reduce their tax liability through the Work Opportunity Tax Credit. To claim this credit, employers must certify the eligibility of new hires by submitting IRS Form 8850 to their state workforce agency within 28 days of the employee starting work.

October 29, 2024: The IRS announced the appointment of its new associate chief counsel for the Passthroughs, Trusts, and Estates office, which will focus on partnerships, S corporations, trusts, and estates.

October 29, 2024: The IRS reminded businesses that they can qualify [...]

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