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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 January 13 – 17, 2025

by , , and | Feb 4, 2025 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025.

TAX CONTROVERSY-RELATED DEVELOPMENTS

January 15, 2025: The US Department of the Treasury (Treasury) and the IRS published final regulations, providing guidance on the resolution of federal tax controversies by the IRS Independent Office of Appeals (IRS Appeals). These final regulations are applicable to requests for IRS Appeals consideration made on or after February 14, 2025.

The Taxpayer First Act of 2019 (TFA) codified IRS Appeals and prescribed that its consideration should be “generally available to all taxpayers” who wished to resolve their federal tax controversies. Proposed regulations published on September 13, 2022, identified 24 exceptions to the term “federal tax controversy.” These exceptions preclude IRS Appeals from considering taxpayer challenges to the constitutionality of statutes and the validity of regulations, as well as the procedural validity of notices and revenue procedures. During the comment period for the proposed regulations, the exceptions regarding statutory/regulatory challenges were the focus of most public comments by far. However, the exceptions were left almost entirely unchanged in the final version of the regulations.

Practice Point: Because the TFA prescribes that IRS Appeals consideration should be “generally available to all taxpayers,” we expect judicial challenges to the validity of the final regulations on Administrative Procedure Act and substantive grounds. In the interim taxpayers should continue asserting their arguments challenging the validity of deficient guidance on constitutional or other grounds.

  • Relatedly, the IRS issued Announcement 2025-6, which describes three pilot initiatives that will test changes to existing Alternative Dispute Resolution programs. These programs are designed to help taxpayers resolve tax disputes earlier and more efficiently. The pilots focus on Fast Track Settlement, a program that allows IRS Appeals to mediate disputes between a taxpayer and the IRS while the case is still within the jurisdiction of the examination function, and Post-Appeals Mediation, a program in which a mediator helps foster a settlement between IRS Appeals and the taxpayer.

CLEAN ENERGY-RELATED DEVELOPMENTS

January 14, 2025: The Treasury and the IRS published final regulations regarding the clean electricity production credit under Internal Revenue Code (Code) Section 45Y and the clean electricity investment credit under Code Section 48E, established by the Inflation Reduction Act of 2022 (IRA). These final regulations provide rules for determining greenhouse gas emissions rates resulting from the production of electricity, petitioning for provisional emissions rates, and determining eligibility for these credits in various circumstances. The final regulations affect all taxpayers who claim the clean electricity production credit with respect to a qualified facility or the clean electricity investment credit with respect to a qualified facility or energy storage technology, as applicable, that is placed in service after 2024.

January 15, 2025: The IRS issued Notice 2025-9, which provides a safe harbor for the incremental cost of certain qualified commercial clean vehicles placed in service in calendar year [...]

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IRS Roundup for November 25 – December 13, 2024

by , and | Dec 17, 2024 | ,

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 11 – November 15, 2024

by , and | Nov 27, 2024 | ,

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).



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Weekly IRS Roundup November 4 – November 8, 2024

by , and | Nov 18, 2024 | ,

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).



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Weekly IRS Roundup September 16 – September 20, 2024

by , and | Sep 27, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16, 2024 – September 20, 2024.

September 16, 2024: The IRS released Internal Revenue Bulletin 2024-38, which include proposed regulations that detail the clean electricity low-income communities bonus credit program under § 48E of the Internal Revenue Code (Code). The regulations outline definitions, requirements, and procedures for applicants seeking to increase their clean electricity investment credit for the taxable year in which the facility is placed in service.

September 16, 2024: The IRS released Revenue Ruling 2024-21, which provides the October 2024 applicable federal rates.

September 17, 2024: The IRS appointed 10 new members to the Electronic Tax Administration Advisory Committee, which serves as a public forum for discussing electronic tax administration issues. These new members, which include state tax officials, cybersecurity experts, and tax professionals, bring diverse expertise from various fields.

September 17, 2024: The IRS recognized its Taxpayer Services Chief for their leadership and efforts to enhance taxpayer services and digital initiatives.

September 18, 2024: The IRS released proposed regulations, which provide a federal income tax credit of up to 30% for costs associated with installing qualified alternative fuel vehicle refueling property in low-income or non-urban census tracts under Code § 30C. The regulations outline eligibility criteria, application procedures, and specific requirements for claiming the credit.

September 18, 2024: The IRS released Notice 2024-64, which modifies Notice 2024-20 by updating the mapping tools used to identify eligible census tracts for the alternative fuel vehicle refueling property credit and extends the period during which taxpayers can rely on these tools. This notice is effective September 18, 2024.

September 18, 2024: The IRS released Notice 2024-67, which provides the 24-month average corporate bond segment rates for September 2024, the yield curve and segment rates for single-employer plans, and the 30-year Treasury securities interest rates.

September 18, 2024: The IRS released Revenue Procedure 2024-37, which provides guidance for issuers of tax-exempt and other tax-advantaged bonds on the procedures for filing claims to recover overpayments of rebate, the penalty in lieu of rebate provisions, and the yield reduction payment provisions under Code § 148. The guidance applies to claims filed on or after October 18, 2024.

September 18, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Pennsylvania that were affected by Tropical Storm Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency, including individuals and households that reside or have a business in Lycoming, Potter, Tioga and Union Counties.

September 19, 2024: The IRS announced it is offering a free webinar on September 26, [...]

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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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