IRS Chief Counsel Archives - TAX CONTROVERSY 360

Weekly IRS Roundup March 4 – March 8, 2024

by Kevin Spencer, Evan Walters and Jeremy Kass | Mar 12, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4, 2024 – March 8, 2024.

March 4, 2024: The IRS released Internal Revenue Bulletin 2024-10, which includes the following:

Revenue Ruling 2024-6, which provides that the overpayment interest rate under § 6621 of the Internal Revenue Code (Code) for the calendar quarter beginning April 1, 2024, will be 8% (7% in the case of a corporation), the underpayment interest rate will be 8% and the interest rate for large corporate underpayments will be 10%. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 5.5%.
Notice 2024-24, which provides updates on the corporate bond monthly yield curve and corresponding spot segment rates for January 2024 used under Code § 417(e)(3)(D), the 24-month average segment rates applicable for February 2024, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
Announcement 2024-13, which revokes § 501(c)(3) determinations for certain organization(s) and stipulates that contributions made to the organization(s) by individual donors are no longer deductible under § 170(b)(1)(A).
Revenue Ruling 2024-04, which provides the March 2024 applicable federal rates.

March 4, 2024: The IRS announced that registration for its 2024 Nationwide Tax Forum is now open, providing tax professionals the opportunity to attend special continuing education sessions in five cities across the nation.

March 4, 2024: The IRS reminded taxpayers that the legal deadline for claiming the Recovery Rebate Credit in 2020 is May 17, 2024. The deadline for claiming the Recovery Rebate Credit in 2021 will be April 15, 2025.

March 5, 2024: The IRS issued final regulations, providing that certain tax-exempt organizations and political entities that earn certain clean energy credits can choose to make an elective payment election. Such an election results in the credits being treated as payments against the electing entity’s federal income tax liabilities with the IRS refunding any excess value. Notice 2024-27, in turn, requests additional comments on situations in which an elective payment election should be permitted with respect to credits purchased in a transfer for which an election under § 6418(a) is made.

March 6, 2024: The IRS reminded taxpayers that they are generally required to report all earned income on their tax returns, including income earned from digital asset transactions, the gig economy and the service industry as well as income from foreign sources.

March 6, 2024: The IRS released a statement acknowledging concerns related to a proposed policy change from January 2 that would limit access to tax return information from the IRS to protect taxpayer confidentiality. In response to comments, the IRS has suspended any changes under the proposed policy.

March 6, 2024: The IRS announced that Margie Rollinson took the oath [...]

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Margie Rollinson Becomes First Female IRS Chief Counsel

by Kevin Spencer | Mar 7, 2024 | Uncategorized

On March 6, 2024, the Internal Revenue Service (IRS) announced that Margie Rollinson has been sworn in as the 49th chief counsel, making her the first female to take on the role. The position has been vacant since Michael Desmond stepped down on January 20, 2021. It took nearly a year for the US Senate to confirm his appointment. We previously reported on Ms. Rollinson’s nomination to the top job.

Ms. Rollinson began her career at Ernst & Young (EY) in 1987, became a partner in 1997 and was eventually named Deputy Director of the National Tax Department, where she also led the International Tax Technical Committee.

In 2013, Ms. Rollinson left EY and joined the IRS Office of Chief Counsel as the Technical Deputy Associate Chief Counsel in the Office of the Associate Chief Counsel International. In 2016, she was named Associate Chief Counsel International and oversaw 100 tax lawyers responsible for issuing published guidance and providing technical guidance.

Practice Point: The IRS Chief Counsel position is appointed by the President of the United States (with the advice and consent of the Senate) and serves as the chief legal advisor to the IRS Commissioner on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Code. Under the Internal Revenue Service Restructuring and Reform Act of 1998, the Chief Counsel reports to both the IRS Commissioner and the General Counsel of the Department of Treasury.

President Biden Announces IRS Chief Counsel Nominee

by Kevin Spencer and Sarah M. Raben | Jun 6, 2023 | Uncategorized

On June 2, 2023, US President Joe Biden announced that he has picked Marjorie Rollinson as the Internal Revenue Service (IRS) Chief Counsel, the top attorney position at the IRS. Rollinson has had a distinguished career in tax service, both in the public and private sectors, and would be the first woman to serve in the role if confirmed by the US Senate. She began her career at Ernst & Young (EY) in 1987, became a partner in 1997 and was eventually named Deputy Director of the National Tax Department where she also led the International Tax Technical Committee.

In 2013, she left EY and joined the Office of Chief Counsel as the Technical Deputy Associate Chief Counsel in the Office of the Associate Chief Counsel International. In 2016, she was named Associate Chief Counsel International where she oversaw 100 tax lawyers responsible for issuing published guidance and providing technical guidance.

Practice Point: The Chief Counsel position has been vacant since Michael Desmond stepped down on January 20, 2021. It took nearly a year for the Senate to confirm his appointment. Senate Finance Committee Chairman Ron Wyden made a statement that he hopes the Senate will be able to process the nomination quickly given the complexity and demands of leading the IRS’s legal team.

Weekly IRS Roundup February 6 – February 10, 2023

by Sarah M. Raben | Feb 13, 2023 | 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 February 6, 2023 – February 10, 2023.

February 6, 2023: The IRS released Internal Revenue Bulletin 2023-6, which highlights the following:

Notice 2023-12: This notice provides updates on the corporate bond monthly yield curve and corresponding spot segment rates and the 24-month average segment rates for January 2023. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.

Notice 2023-13: This notice sets forth a proposed revenue procedure establishing the Service Industry Tip Compliance Agreement (SITCA) program. SITCA is a voluntary tip reporting program between the IRS and employers in the service industry that is designed to enhance tax compliance through the use of agreements instead of traditional audit techniques.

Revenue Procedure 2023-14: This guidance provides the tables of limitations on depreciation deductions for owners of passenger automobiles placed in during calendar year 2023 and the table dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2023.

Revenue Ruling 2023-3: This revenue ruling provides the applicable federal rates for federal income tax purposes for February 2023. The short-term federal interest rate is 4.47%, the mid-term is 3.82% and the long-term rate is 3.86%.

February 6, 2023: The IRS released Tax Tip 2023-14, highlighting the Taxpayer Bill of Rights, which include the Right to be Informed. Taxpayers have the right to know what they need to do to comply with the tax laws.

February 6, 2023: The IRS and the US Department of the Treasury (Treasury) announced a new program for service industry tip reporting. The proposed SITCA program is designed to take advantage of advancements in point-of-sale, time and attendance systems, and electronic payment settlement methods to improve tip reporting compliance. The proposed program would also decrease taxpayer and IRS administrative burdens and provide more transparency and certainty to taxpayers.

February 6, 2023: The IRS announced special Saturday hours for the next four months at Taxpayer Assistance Centers across the country. The Saturday hours will take place on February 11, March 11, April 8 and May 13 from 9:00 am to 4:00 pm.

February 7, 2023: The IRS released Tax Tip 2023-15, providing information to help business travelers properly claim travel business deductions.

February 8, 2023: The IRS released Announcement 2023-6, which notifies the public that it intends to issue opinion letters by February 28, 2023, for preapproved defined benefit plans that were updated for changes in plan qualification requirements and filed with the IRS during the third six-year remedial amendment cycle. This announcement also notifies the public of the date by which an adopting employer [...]

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