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Weekly IRS Roundup August 12 – August 16, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Aug 22, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12, 2024 – August 16, 2024.

August 12, 2024: The IRS released Internal Revenue Bulletin 2024-33, which includes final regulations on the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations under Section 367 of the Internal Revenue Code. These regulations, effective July 17, 2024, also cover the consequences for recipients of such stock or securities and subsequent inbound nonrecognition transactions.

August 12, 2024: The IRS reminded taxpayers of the option to electronically request relief for certain late-filed international documents, such as gain recognition agreements and dual consolidated losses, using eFax. This digital option, introduced in August 2023, aims to streamline the process and reduce the burden of paper documentation.

August 12, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Minnesota that were affected by severe weather that began on June 16, 2024. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in Blue Earth County or one of the other 24 specified Minnesota counties.

August 13, 2024: The IRS released an updated Written Information Security Plan (WISP) to help tax professionals protect against identity theft and data breaches. As part of the Protect Your Clients; Protect Yourself campaign, WISP highlights best practices like multifactor authentication and mandatory reporting of security incidents affecting more than 500 individuals.

August 13, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Vermont that were affected by Hurricane Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by FEMA, including individuals and households that reside or have a business in any of the 14 Vermont counties.

August 14, 2024: The IRS encouraged qualifying businesses, tax-exempt organizations and government entities to complete pre-filing registration for elective pay related to 2023 projects at least 120 days before they file their tax returns. By registering, taxpayers can earn certain tax credits under the Inflation Reduction Act of 2022 and the CHIPS and Science Act.

August 15, 2024: The IRS announced the opening of the application period for the 2025 Compliance Assurance Process program, which will run from September 4, 2024, to October 31, 2024. This program is available to certain privately held C corporations and publicly traded corporations with at least $10 million in assets.

August 15, 2024: The IRS reminded truckers that the deadline to file IRS Form 2290, Heavy Highway [...]

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Weekly IRS Roundup November 1 – November 5, 2021

by McDermott Will & Emery | Nov 8, 2021 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 1, 2021 – November 5, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 1, 2021: The IRS released a memorandum, providing guidance on the refund recoupment process for employees of Specialty Collection Offer in Compromise. Beginning with offers accepted on or after November 1, 2021, the offer in the compromise refund recoupment process will no longer be applicable for offsetting tax periods included on Form 656.

November 1, 2021: The IRS released a memorandum, extending certain temporary guidance related to taxpayer contact, initial contact and asset evaluations with respect to Internal Revenue Manual SBSE-05-0321-0019, Extension of Temporary Guidance for Field Collection and Specialty Collection Offers in Compromise Procedures During the COVID-19 Pandemic and Resumption of NFTL Procedures. The memorandum also extends the waiver that requires a field call prior to acceptance of certain Offers in Compromise in accordance with IRM 5.8.4.8(10) until January 31, 2022. The temporary guidance regarding Notice of Federal Tax Lien (NFTL) determinations and filings was not extended.

November 2, 2021: The IRS released the IRS Chief Counsel code and subject matter directory for November 2021.

November 3, 2021: The IRS published a news release, reminding taxpayers that a special tax provision will allow more Americans to easily deduct up to $600 in donations to qualifying charities on their 2021 federal income tax return. A temporary law change now permits them to claim a limited deduction on their 2021 federal income tax returns for cash contributions made to qualifying charitable organizations.

November 3, 2021: The IRS published FAQs concerning carried interest reporting details for partnerships. The purpose of the FAQs is to provide guidance relating to both pass-through entity filing and reporting requirements and owner taxpayer filing requirements in accordance with US Department of the Treasury (Treasury) regulations revised in T.D. 9945 (concerning guidance under Section 1061, which recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains).

November 3, 2021: The IRS published a news release, announcing that victims of Hurricane Ida in parts of Connecticut now have until January 3, 2022, to file various individual and business tax returns and make tax payments.

November 3, 2021: The IRS and Treasury published a notice and request for comments concerning third-party disclosure requirements in IRS regulations. Written comments are due on or before January 3, 2022.

November 5, 2021: The IRS published a practice unit concerning expense allocation and apportionment when calculating a foreign tax credit under Section 904. The practice unit was revised to correct an error and supersedes the August 29, 2016, practice unit with the same title.

November 5, 2021: The IRS and Treasury
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Weekly IRS Roundup October 4 – October 8, 2021

by McDermott Will & Emery | Oct 11, 2021 | IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 4, 2021 – October 8, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

October 4, 2021: The IRS released a practice unit, providing tax law and audit steps for reviewing a reseller’s uniform capitalization cost computations under section 263A. The practice unit focuses on the simplified production method and does not cover the final section 263A Treasury Regulations that were effective November 20, 2018.

October 4, 2021: The IRS published a news release, announcing 18 self-study seminars available online through the IRS Nationwide Tax Forums. The seminars cover topics such as the gig economy and virtual currency.

October 4, 2021: The IRS published instructions for Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting (Individuals)) concerning:

Guidance under section 1446(f) (withholding on partnership interest dispositions)
New lines 6a and 6b (addressing foreign tax ID number (FTIN) matters)
Tax treaty benefits claims (requiring representations)
Section 6050Y reporting (covering life insurance contracts and reportable death benefits)
Electronic signatures (updated to reflect new guidance)

October 5, 2021: The IRS published a news release, announcing that Free File remains available through October 15 for taxpayers who still need to file their 2020 tax returns. Free File is the IRS’s public-private partnership with tax preparation software industry leaders to provide their brand name products for free.

October 5, 2021: The IRS released a memorandum, expanding the criteria for collection due process cases that qualify for a rapid response appeals process under IRM 8.22.6.2 and related subsections.

October 5, 2021: The IRS released a memorandum concerning interim guidance regarding the IRS Independent Office of Appeals’ steps and procedures for its nationwide pilot program: The Appeals Electronic Case Files Initiative for Large Business & International (LB&I) report generation software (RGS) examination cases. This guidance is applicable to LB&I RGS International Individual Compliance cases only and excludes other large cases such as Tax Equity and Fiscal Responsibility Act of 1982 cases, Bipartisan Budget Act of 2015 cases and Syndicated Conservation Easement cases.

October 5, 2021: The IRS released a memorandum updating procedures where an organization requests a change in a section 501 subsection during the application process by submitting one application form to replace a different application form. The procedures are effective 30 days after issuance of the memorandum and supersedes those in TEGE-07-0421-0010 (April 29, 2021).

October 7, 2021: The IRS published a program letter indicating that, in Fiscal Year 2022, Tax Exempt (TE)/Government Entities (GE) commissioners expect to invest in new resources to expand outreach to the exempt sector as well as increase their enforcement staff.

October 8, 2021: The IRS released its weekly list of written [...]

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Weekly IRS Roundup August 12 – August 16, 2024

Weekly IRS Roundup November 1 – November 5, 2021

Weekly IRS Roundup October 4 – October 8, 2021

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