Associate Chief Counsel offices Archives

Weekly IRS Roundup December 30, 2024 – January 3, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2024 – January 3, 2025.

December 30, 2024: The IRS released Internal Revenue Bulletin 2025-1, which includes the following:

Revenue Procedure 2025-1, which contains the revised procedures for letter rulings and information letters issued by the different associate chief counsel offices. This revenue procedure also contains the revised procedures for determination letters issued by the Large Business and International Division, the Small Business/Self-Employed Division, the Wage and Investment Division, and the Tax Exempt and Government Entities (TE/GE) Division.
Revenue Procedure 2025-2, which explains when and how associate chief counsel offices should provide advice in technical advice memoranda (TAM) as well as taxpayers’ rights when a field office requests a TAM.
Revenue Procedure 2025-3, which provides a revised list of Internal Revenue Code (Code) areas under the jurisdiction of the following associate chief counsel offices: Corporate; Financial Institutions and Products; Income Tax and Accounting; Passthroughs and Special Industries; Procedure and Administration; and Employee Benefits, Exempt Organizations, and Employment Taxes. These relate to matters in which the IRS will not issue letter rulings or determination letters.
Revenue Procedure 2025-4, which provides guidance on the types of advice the IRS offers to taxpayers on issues under the jurisdiction of the IRS Commissioner, TE/GE Division, and Employee Plans Rulings and Agreements. It also details the procedures that apply to requests for determination letters and private letter rulings.
Revenue Procedure 2025-5, which provides the procedures for issuing determination letters on issues under the jurisdiction of the Exempt Organizations Rulings and Agreements. It also explains the procedures for issuing determination letters on tax-exempt statuses for organizations applying under Code Section 501 or 521, private foundation status, and other determinations related to tax-exempt organizations. Additionally, the revenue procedure applies to revocation or modification of determination letters and provides guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under Code Section 7428.
Revenue Procedure 2025-7, which provides the areas under the jurisdiction of the associate chief counsel (international) in which letter rulings and determination letters will not be issued.

December 30, 2024: The IRS published Treasury Decision 10018, which contains final regulations regarding the filing of consolidated returns by affiliated corporations. They modify the consolidated return regulations to reflect statutory changes, update language to remove antiquated or regressive terminology, and enhance clarity. The IRS separately issued proposed regulations under which a transferee’s assumption of certain liabilities from a member of the same consolidated group will not reduce the transferor’s basis in the transferee’s stock received in the transfer.

December 30, 2024: The IRS published final regulations clarifying when tax-exempt bonds are considered retired for federal income tax purposes under Code Section 103. The regulations affect state and local governments issuing tax-exempt bonds [...]

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Weekly IRS Roundup January 3 – January 6, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023.

January 3, 2023: The IRS released Internal Revenue Bulletin 2023-1, which highlights the following:

Revenue Procedure 2023-1: This contains the revised procedures for letter rulings and information letters issued by the different offices of the Associate Chief Counsel. This procedure also contains the revised procedures for determination letters issued by the Large Business and International (LB&I) Division, the Small Business/Self Employed Division, the Wage and Investment Division and the Tax Exempt and Government Entities (TE/GE) Division.

Revenue Procedure 2023-2: This procedure explains when and how an associate office within the Office of Chief Counsel provides technical advice conveyed in technical advice memoranda (TAM). It also explains the rights a taxpayer has when a field office requests a TAM.

Revenue Procedure 2023-3: This procedure provides a revised list of areas of the Internal Revenue Code (IRC) under the jurisdiction of the Associate Chief Counsel offices of Corporate, Financial Institutions and Products, Income Tax and Accounting, Passthroughs and Special Industries, Procedure and Administration, Employee Benefits, Exempt Organizations and Employment Taxes. These relate to matters in which the IRS will not issue letter rulings or determination letters.

Revenue Procedure 2023-4: This document provides guidance relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the TE/GE Division, Employee Plans Rulings and Agreements and the procedures that apply to requests for determination letters and private letter rulings.

Revenue Procedure 2023-5: This provides the procedures for issuing determination letters on items under the jurisdiction of the Director, Exempt Organizations Rulings and Agreements.

Revenue Procedure 2023-7: This procedure provides the areas under the jurisdiction of the Associate Chief Counsel International in which rulings will not be issued.

January 3, 2023: The IRS encouraged taxpayers to review the Taxpayer Bill of Rights, which may help resolve filing season questions. Each month, Tax Tips will focus on one of the 10 categories of taxpayer rights.

January 3, 2023: The IRS issued Revenue Procedure 2023-10, which prescribes the loss payment patterns for the 2022 determination year and the discount factors for the 2022 accident year for use by insurance companies in computing discounted unpaid losses under Section 846 and discounted estimated salvage recoverable under Section 832.

January 4, 2023: The IRS reminded taxpayers that final 2022 quarterly estimated tax payments are due January 17. The IRS recommends for taxpayers who earn or receive income not subject to tax withholding, such as self-employed individuals or independent contractors, to pay their taxes quarterly.

January 5, 2023: The IRS released its latest executive column in A Closer [...]

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