TAX CONTROVERSY 360

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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Weekly IRS Roundup October 7 – October 11, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Oct 24, 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 7, 2024 – October 11, 2024.

October 7, 2024: The IRS released Internal Revenue Bulletin 2024-41, which includes the following:

Notice 2024-69, which provides the inflation adjustment factor and reference price for the renewable electricity production credit under 45 of the Internal Revenue Code (Code) for calendar year 2024. The inflation adjustment factor and reference price are used to determine the availability and amount of the credit for electricity produced from qualified energy resources in the United States or its possessions.
Revenue Procedure 2024-36, which updates the requirements for substitute IRS Forms W-2c and W-3c by detailing the specifications for red-ink and black-and-white forms as well as the electronic filing procedures. The new guidelines emphasize the importance of conforming to these specifications to avoid penalties and ensure proper processing by the IRS and Social Security Administration.

October 7, 2024: The IRS issued final regulations, which qualify certain syndicated conservation easement transactions as “listed transactions,” requiring their disclosure on IRS Form 8886, Reportable Transaction Disclosure Statement, and Form 8918, Material Advisor Disclosure Statement, by certain participants and material advisors. These regulations aim to prevent the use of inflated appraisals to claim unwarranted tax deductions and are effective as of October 8, 2024.

October 7, 2024: The IRS reminded taxpayers that the deadline to file their 2023 federal income tax returns is October 15, 2024. However, taxpayers in combat zones, disaster areas, and those affected by the terrorist attacks in Israel have extended deadlines to file and pay their taxes.

October 7, 2024: The IRS issued proposed regulations, which clarify that entities entirely owned by Indian tribal governments will not be recognized as separate entities for federal tax purposes or be subject to federal income tax. The regulations also provide that these entities may receive the value of certain energy credits under the Inflation Reduction Act of 2022.

October 10, 2024: The IRS announced it is processing approximately 400,000 Employee Retention Credit claims and is working on expediting these claims while ensuring compliance and preventing improper payments.

October 10, 2024: The IRS announced that the projected gross tax gap, which reflects the difference between true tax liability and taxes paid on time, for tax year 2022 has increased to $696 billion. The IRS attributes this increase to economic growth rather than changes in taxpayer behavior.

October 11, 2024: The IRS issued Revenue Procedure 2024-39, which grants certain entities an automatic six-month extension to file IRS Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under Section 6033(e) of the Code), for making elective payment elections under Code § 6417. This relief aims to assist entities unfamiliar with the filing process and those facing electronic filing limitations.

October 11, 2024: The IRS [...]

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