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Weekly IRS Roundup October 28 – November 1, 2024

by , and | Nov 4, 2024 | ,

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 March 13 – March 17, 2023

by | Mar 20, 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 February 20 – February 26, 2022

by | Feb 28, 2022 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 20, 2022 – February 26, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

February 22, 2022: The IRS issued a correction to final regulations published on January 25, 2022, relating to the treatment of domestic partnerships that hold stock in foreign corporations.

February 22, 2022: The IRS issued a news release announcing the release of an updated list containing information about Low Income Taxpayer Clinics available around the country.

February 23, 2022: The IRS issued Revenue Ruling 2022-05 and an accompanying news release, setting forth the overpayment and underpayment interest rates under Section 6621 of the Code for Q2 2022.

February 24, 2022: The IRS issued final regulations relating to required minimum distributions under Section 401 of the Code with respect to certain employee pension and retirement plans.

February 24, 2022: The IRS issued a further correction to final regulations published on January 25, 2022, relating to the treatment of domestic partnerships that hold stock in foreign corporations.

February 24, 2022: The IRS issued a news release promoting its “Where’s My Refund?” online and mobile tools as ways for taxpayers to check on the status of their tax refunds.

February 24, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the Premium Tax Credit under Section 36B of the Code, as expanded by the American Rescue Plan Act of 2021 (ARPA).

February 25, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.



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Weekly IRS Roundup March 18 – 22, 2019

by | Mar 25, 2019 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 18 – 22, 2019.

March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on proposed regulations on hybrid arrangements under Sections 245A and 267A of the code.

March 19, 2019: The IRS issued Revenue Procedure 2019-14 providing issuers of qualified mortgage bonds and issuers of mortgage credit certificates the nationwide average purchase price for residences located in the United States, and the average area purchase price safe harbors for residences located in certain statistical areas.

March 20, 2019: The IRS requested comments on the treatment of distributions by foreign corporations and coordination with nonrecognition provisions. Comments should be received by May 20, 2019.

March 20, 2019: The IRS issued a news release announcing the conclusion of what it refers to as the “dirty dozen” list of tax scams.

March 21, 2019: The IRS issued Revenue Ruling 2019-09 suspending two revenue rulings from 1957 pending the completion of a study regarding the active trade or business requirement under Sections 355(a)(1)(C) and (b) of the code.

March 22, 2019: The IRS issued Proposed Regulations on new information reporting requirements for certain life insurance companies under Section 6050Y of the code.

March 22, 2019: The IRS issued Notice 2019-25 modifying and superseding Notice 2019-11. The notice increases the availability of the waiver of the addition to tax for underpayment of estimated income tax for certain individuals for 2018.

March 22, 2019: The IRS issued Notice 2019-26 updating mortality improvement rates and static mortality tables for determining the minimum funding requirements under § 430(h)(3) for 2020. The notice also updates the minimum present value under § 417(e)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2020 calendar year.

Special thanks to Terence McAllister in our New York office for this week’s roundup.



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