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

by , and | Jan 13, 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 December 23 – December 27, 2024

by , and | Jan 9, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23, 2024 – December 27, 2024.

December 23, 2024: The IRS released Internal Revenue Bulletin 2024-52, which includes the following:

  • Treasury Decision 10015: These final regulations update the previous regulations under Section 48 of the Internal Revenue Code (Code), which provides for an investment tax credit for energy property (energy credit), and respond to changes made by the Inflation Reduction Act of 2022 (IRA).
    • The final regulations update the types of energy property eligible for the energy credit, including additional types of energy property added by the IRA; clarify the application of new credit transfer rules to recapture because of failure to satisfy the prevailing wage requirements, including notification requirements for eligible taxpayers; and include qualified interconnection costs in the basis of certain lower-output energy properties.
    • The final regulations also provide rules generally applicable to energy property, such as rules regarding functionally interdependent components, property that is an integral part of an energy property, application of the “80/20 rule” to retrofitted energy property, dual use property, ownership of components of an energy property, energy property that may be eligible for multiple federal income tax credits, and the election to treat qualified facilities eligible for the renewable electricity production credit under Code Section 45 as property eligible for the energy credit.
  • Notice 2024-82, which sets forth the 2024 Required Amendments List. The list applies to both individually designed plans under Code Section 401(a) and individually designed plans that satisfy the requirements of Code Section 403(b).
  • Notice 2024-86, which announces the extension of certain timeframes under the Employee Retirement Income Security Act of 1974 and the Code for group health plans; disability and other welfare plans; pension plans; and participants, beneficiaries, qualified beneficiaries, and claimants of these plans affected by Hurricane Helene, Tropical Storm Helene, or Hurricane Milton.
  • Revenue Procedure 2024-42, which updates the list of jurisdictions with which the United States has in effect a relevant information exchange agreement or an automatic exchange relationship under Treasury Regulation §§ 1.6049-4(b)(5) and 1.6049-8(a).
  • Announcement 2024-42, which provides a copy of the competent authority arrangement entered into by the competent authorities of the US and the Kingdom of Norway under paragraph 2 of Article 27 (Mutual Agreement Procedure) of the Convention between the US and Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Property, signed on December 3, 1971.
  • The IRS issued a notice of proposed rulemaking, setting forth proposed regulations related to the definition of “qualified nonpersonal use vehicles.” Qualified nonpersonal use vehicles are excepted from the substantiation requirements that apply to certain listed property. The proposed regulations add unmarked vehicles used by firefighters or members of a rescue squad or ambulance crew as a new [...]

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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 18 – November 22, 2024

by , and | Dec 2, 2024 | ,

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).



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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 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 October 7 – October 11, 2024

by , and | Oct 24, 2024 | ,

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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Weekly IRS Roundup September 30 – October 4, 2024

by , and | Oct 15, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30, 2024 – October 4, 2024.

September 30, 2024: The IRS released Internal Revenue Bulletin 2024-40, which includes the following:

  • Revenue Ruling 2024-20, which provides the terminal charge and Standard Industry Fare Level mileage rates for valuing noncommercial flights on employer-provided aircraft for the second half of 2024.
  • Treasury Decision 9991, which contains final regulations that provide guidance on the consistent basis requirement under 1014(f) of the Internal Revenue Code (Code), applicable to recipients of certain property from a decedent, and the reporting requirements under Code § 6035, applicable to executors and other persons required to file an estate tax return. The final regulations adopt the 2016 proposed regulations (with some modifications) and are designed to ensure accurate reporting and compliance.
  • Proposed regulations, which amend the definition of “coverage month” to include any month where the premium paid, including advance payments, is sufficient to maintain an individual’s coverage from being terminated for that month when computing their premium tax credit (PTC). The proposed regulations also modify certain rules for calculating an individual taxpayer’s health insurance PTC and clarify eligibility criteria for state basic health programs.
  • Proposed regulations, which update the qualified domestic trust rules under Code 2056A by removing outdated references to align with current IRS procedures and revising filing requirements and addresses. The proposed regulations primarily affect estates passing property to noncitizen spouses.

September 30, 2024: The IRS released draft IRS Form 7217, Partner’s Report of Property Distributed by a Partnership, which requires partners to report property distributions from partnerships beginning in tax year 2024. Distributions consisting solely of money or marketable securities treated as money are excluded.

September 30, 2024: The IRS released Notice 2024-70, which extends the replacement period under Code § 1033(e) for livestock sold or exchanged because of drought conditions in specified counties across 41 US states, allowing more time for eligible farmers and ranchers to replace livestock.

October 1, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Illinois that were affected by severe weather that began on July 13, 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 the following counties: Cook, Fulton, Henry, St. Clair, Washington, Will, and Winnebago.

October 1, 2024: The IRS announced it is seeking volunteers for the Volunteer Income Tax Assistance and Tax Counseling for the Elderly programs to provide free tax services during the upcoming filing season. Interested individuals can sign up from October to January, with flexible hours and various roles [...]

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Weekly IRS Roundup September 23 – September 27, 2024

by , and | Oct 7, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23, 2024 – September 27, 2024.

September 23, 2024: The IRS released Internal Revenue Bulletin 2024-39, which includes the following:

  • Announcement 2024-39, which revokes the determination for specified organizations under § 501(c)(3) of the Internal Revenue Code (Code) and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).
  • Proposed regulations, which update and modify the 2017 proposed regulations, including the timing for making and revoking the proposed mark-to-market election and the Code § 954 currency elections. Taxpayers may rely on the regulations until they are finalized, but the changes to the 2017 proposed regulations take effect upon their publication in the Federal Register, which is expected on August 20, 2024.

September 23, 2024: The IRS announced the appointment of a new chief for its Independent Office of Appeals. They will be responsible for managing the resolution of tax disputes between taxpayers and the IRS without litigation.

September 24, 2024: The IRS released Revenue Procedure 2024-38, which provides guidance on the income requirements for qualified residential rental projects financed with exempt facility bonds under Code § Section 142(d) and for qualified low-income housing projects under Code § 42. The guidance will take effect on October 24, 2024.

September 26, 2024: The IRS introduced a supplemental claim process to assist payroll companies and third-party payers in resolving incorrect claims for the Employee Retention Credit. This process allows third-party payers to correct or withdraw claims for taxpayers who are ineligible for the credit.

September 26, 2024: The IRS released Revenue Ruling 2024-22, determining that the Bourse de Montréal (MX) is a qualified board or exchange under Code § 1256(g)(7)(C), provided it holds a valid Order of Registration from the Commodity Futures Trading Commission. This ruling is effective for MX contracts entered into on or after November 1, 2024.

September 27, 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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