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IRS Releases Guidance on Cryptocurrency Hard Forks

by , , and | May 6, 2021 | ,

On April 9, 2021, the Internal Revenue Service (IRS) released Chief Counsel Advice memo 202114020 (Hard Fork CCA), which details the potential tax consequences for taxpayers who held Bitcoin prior to the August 1, 2017, Bitcoin hard fork. While the Hard Fork CCA concerns the taxation of a particular cryptocurrency transaction, it has additional significance because it adds to the limited guidance available regarding the proper taxation of cryptocurrency more generally.

IN DEPTH

A cryptocurrency hard fork occurs when the blockchain on which cryptocurrency transactions are recorded permanently splits. The holder of the cryptocurrency generally has no control or notice that the hard fork is about to occur. The result is two separate blockchains with two separate sets of rules for recording transactions.

Bitcoin underwent a hard fork on August 1, 2017, and resulted in two separate sets of protocols for Bitcoin, as well as a new cryptocurrency called Bitcoin Cash. The result of this hard fork was that individuals holding Bitcoin in a distributed ledger now held a unit of Bitcoin Cash for each unit of Bitcoin previously held.

The Hard Fork CCA reached two conclusions concerning the Bitcoin hard fork. First, it determined that a taxpayer who received Bitcoin Cash because of the hard fork has gross income pursuant to Internal Revenue Code (IRC) section 61. Second, it determined that the date of receipt and fair market value of the income depends on when the taxpayer obtains dominion and control over the Bitcoin Cash. The Hard Fork CCA relies on the statutory language of IRC Section 61(a)(3) and the well-established case law of Commissioner v. Glenshaw Glass Company (348 U.S. 426, 431 (1955) in reaching this result. Those sources define gross income as “all income from whatever source derived,” and provide that all gains or undeniable accessions to wealth, clearly realized, over which a taxpayer has complete dominion are included in gross income. The Hard Fork CCA also concludes that an impacted taxpayer gains dominion over Bitcoin Cash when they have the ability to sell, transfer or exchange the Bitcoin Cash.

Despite the fact that the Hard Fork CCA deals specifically with the consequences of the Bitcoin hard fork, the dearth of IRS guidance on the taxation of cryptocurrencies means the Hard Fork CCA will likely have broad importance to taxpayers who invest in other cryptocurrencies and similar digital assets. Most taxpayers hold cryptocurrencies through a cryptocurrency exchange platform. Coinbase, for example, which recently underwent a highly publicized initial public offering (IPO) and IRS summons for information concerning its participants, is one of the most popular cryptocurrency exchanges. (Additional detail regarding the Coinbase summons is available on our Tax Controversy 360 blog.) After a hard fork, some exchanges immediately adopt the new cryptocurrency and permit its use on the exchange; however, others only do so after a period of evaluation, if ever. The Hard Fork CCA takes the position that a taxpayer who privately holds their Bitcoin using a private key to [...]

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Weekly IRS Roundup April 26 – April 30, 2021

by | May 3, 2021 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 26, 2021 – April 30, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 26, 2021: The IRS issued Revenue Procedure 2021-23, making superseding changes to earlier Revenue Procedures related to the Child Tax Credit under section 24 of the Code, the Earned Income Credit under section 32 of the Code and the Premium Tax Credit under section 36B of the Code in order to reflect statutory amendments made by the American Rescue Plan Act of 2021 (ARPA).

April 26, 2021: The IRS issued a news release reporting the results of its March 2021 inaugural National Virtual Settlement Month, an IRS-coordinated nationwide initiative to provide pro bono legal advice to pro se US Tax Court litigants.

April 27, 2021: The IRS issued corrections to final regulations published in December 2020 regarding the elimination of the deduction for expenses associated with certain employer-provided transportation and commuting benefits under section 274 of the Code.

April 27, 2021: The IRS issued a news release, describing various electronic services it provides and urging taxpayers and tax professionals to use such services to speed up the processing of tax returns, payments and refunds.

April 28, 2021: The IRS issued a news release announcing a seventh round of Economic Impact Payments consisting of nearly two million payments totaling more than $4.3 billion, bringing the total amount of disbursements under ARPA to approximately 163 million payments worth approximately $384 billion.

April 29, 2021: The IRS issued a news release, providing information and resources to assist with tax compliance by gig economy workers and taxpayers who claimed unemployment compensation in 2020.

April 29, 2021: The IRS issued a news release, reminding taxpayers of the availability of tax-filing extensions upon request and listing certain categories of taxpayers who automatically obtain extensions without request.

April 30, 2021: The IRS issued Announcement 2021-8, listing attorneys, Certified Public Accountants (CPAs) and other practitioners who have received disciplinary sanctions for violating the regulations governing practice before the IRS.

April 30, 2021: The IRS issued a news release announcing the release of updated 2021 versions of Schedules K-2 and K-3 for Forms 1065, 1120-S and 8865. The updated Schedules are intended to provide greater clarity regarding the reporting of certain international tax items with respect to pass-through entities.

April 30, 2021: The IRS issued a news release announcing that it is now accepting grant applications by eligible organizations under the Tax Counseling for the Elderly (TCE) and Volunteer Income Tax Assistance (VITA) programs, which provide tax assistance services to elderly taxpayers and underserved communities, respectively.

April 30, 2021: The IRS released its weekly list of written determinations (e.g., [...]

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DOJ and IRS’ Analysis of Crypto Records and Work with Private Experts and International Partners Leads to Arrest

by and | Apr 30, 2021 | ,

US law enforcement continues to make no secret of their efforts to work closely with experts and overseas partners to prosecute those involved in virtual currency transactions who attempt to rely on its purported anonymity to commit financial crimes. Tuesday’s arrest of Roman Sterlingov, a dual citizen of Russia and Sweden and alleged operator of Bitcoin Fog, in Los Angeles is a clear case that these efforts are paying dividends. In a criminal complaint filed by the US Attorney’s Office for the District of Columbia, Sterlingov is accused of laundering hundreds of millions of dollars’ worth of bitcoin. According to a statement of facts accompanying the complaint filed in the District of Columbia, Sterlingov was allegedly running “an illicit bitcoin money transmitting and money laundering service.” (Case 1:21-mj-00400-RMM Document 1-1 Filed 04/26/21.) Notably, investigators from the Internal Revenue Service (IRS) and Federal Bureau of Investigation (FBI) were able to obtain records of Sterlingov’s True Name accounts at several cryptocurrency exchanges. Investigators also analyzed bitcoin transactions, email records, financial records and internet service provider records. The investigation and arrest come at a time when the IRS, together with other enforcement agencies, are taking a hard look at cryptocurrency activity and have recently issued John Doe summonses to two virtual currency exchanges.

The collaboration with private experts and international partners is clear from the press release issued by the US Department of Justice (DOJ). In recognizing the many agencies that assisted in the investigation, the DOJ specifically stated that essential support was provided by Excygent, which is described on its website “as a highly specialized, professional services firm that assists organizations in both the public and private sectors with cybercrime investigative and analysis capabilities.” The DOJ also listed several US agencies that provided invaluable assistance and went on to include international partners: Europol, the Swedish Economic Crime Authority, the Swedish Prosecution Authority, the Swedish Police and the General Inspectorate of Romanian Police, Directorate for Combatting Organized Crime and the Directorate for Investigating Organized Crime and Terrorism. This ability to collaborate successfully will most likely serve as a blueprint for future investigations.

Practice Point: As we noted in our blog post, “Finding John Doe: IRS Steps up Enforcement Efforts to Take the Anonymity Out of Virtual Currency,” the time is now for those who have engaged in a virtual currency transaction to assess any potential tax and criminal implications, and businesses in this industry should carefully review their policies and processes to ensure that they address potential tax avoidance and anti-money laundering risks associated with their operations. The IRS is working closely with its new partners (i.e., industry experts and foreign law enforcement) to address any noncompliance. As announced recently by US President Joe Biden, he plans to give them the resources to do more on enforcement.



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Weekly IRS Roundup April 19 – April 23, 2021

by | Apr 26, 2021 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 19, 2021 – April 23, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 19, 2021: The IRS issued a news release announcing the establishment of a new office, the IRS Office of Promoter Investigations (OPI), which will address promoters of abusive tax avoidance transactions, such as certain syndicated conservation easements and micro-captive insurance arrangements.

April 20, 2021: The IRS issued a news release reminding taxpayers of common filing errors that could delay the processing of returns and refunds.

April 21, 2021: The IRS issued a fact sheet and an accompanying news release, providing details about small business tax credits available under the American Rescue Plan Act of 2021 (ARPA), including credits for the cost of providing leave for employees who are unable to work because of COVID-19 and credits for the cost of providing leave for employees to receive, or recover from, COVID-19 vaccinations.

April 22, 2021: The IRS issued Revenue Procedure 2021-20 and an accompanying news release, providing a safe harbor for certain businesses that received COVID-related Paycheck Protection Program loans and did not deduct the associated expenses for the 2020 taxable year. In response to recent legislation permitting the deduction of such expenses, the Revenue Procedure provides that such businesses may deduct such expenses for the 2021 taxable year in lieu of filing an amended return for the 2020 taxable year.

April 22, 2021: The IRS issued Revenue Procedure 2021-21, waiving the residence requirements to qualify for benefits under section 911 of the Code for the 2020 taxable year, with respect to certain individual taxpayers who departed from Iraq after March 25, 2020.

April 22, 2021: The IRS issued a news release announcing a sixth round of Economic Impact Payments consisting of nearly two million payments totaling nearly $3.4 billion, bringing the total amount of disbursements under ARPA to approximately 161 million payments worth more than $379 billion.

April 23, 2021: 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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IRS Extends Use of Digital Signatures for Certain Forms until End of 2021

by , and | Apr 23, 2021 |

The list of Internal Revenue Service (IRS) forms that can be digitally signed continues to grow. On August 28, 2020, the IRS issued a memorandum indicating that it would accept the use of digital signatures on various IRS forms because of the restrictions involved with the COVID-19 pandemic. In September 2020, it announced the addition of several more forms. Then, on April 15, 2021, the IRS announced it is extending the authorization to a large number of IRS forms until December 31, 2021. The IRS has not specified which digital signature product tax professionals must use but has advised that there are several commercial products available.

The current list of IRS forms that can be digitally signed are:

  • Form 11-C, Occupational Tax and Registration Return for Wagering
  • Form 1066, U.S. Income Tax Return for Real Estate Mortgage Investment Conduit
  • Form 637, Application for Registration (for Certain Excise Tax Activities)
  • Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return
  • Form 706-A, U.S. Additional Estate Tax Return
  • Form 706-GS(D), Generation-Skipping Transfer Tax Return for Distributions
  • Form 706-GS(D-1), Notification of Distribution From a Generation-Skipping Trust
  • Form 706-GS(T), Generation-Skipping Transfer Tax Return for Terminations
  • Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts
  • Form 706, Schedule R-1, Generation-Skipping Transfer Tax
  • Form 706-NA, U.S. Estate (and Generation-Skipping Transfer) Tax Return
  • Form 709, U.S. Gift (and Generation-Skipping Transfer) Tax Return
  • Form 730, Monthly Tax Return for Wagers
  • Form 1120-C, U.S. Income Tax Return for Cooperative Associations
  • Form 1120-FSC, U.S. Income Tax Return of a Foreign Sales Corporation
  • Form 1120-H, U.S. Income Tax Return for Homeowners Associations
  • Form 1120-IC DISC, Interest Charge Domestic International Sales — Corporation Return
  • Form 1120-L, U.S. Life Insurance Company Income Tax Return
  • Form 1120-ND, Return for Nuclear Decommissioning Funds and Certain Related Persons
  • Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return
  • Form 1120-REIT, U.S. Income Tax Return for Real Estate Investment Trusts
  • Form 1120-RIC, U.S. Income Tax Return for Regulated Investment Companies
  • Form 1120-SF, U.S. Income Tax Return for Settlement Funds (Under Section 468B)
  • Form 1127, Application for Extension of Time for Payment of Tax Due to Undue Hardship
  • Form 1128, Application to Adopt, Change or Retain a Tax Year
  • Form 2678, Employer/Payer Appointment of Agent
  • Form 3115, Application for Change in Accounting Method
  • Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
  • Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner
  • Form 4421, Declaration — Executor’s Commissions and Attorney’s Fees
  • Form 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes
  • Form 8038, Information Return for Tax-Exempt Private Activity Bond Issues
  • Form 8038-G, Information Return for Tax-Exempt Governmental Bonds
  • Form 8038-GC; Information Return for Small Tax-Exempt Governmental Bond Issues, Leases, and Installment Sales
  • Form 8283, Noncash Charitable Contributions
  • Form 8453 series, Form 8878 series and Form 8879 series regarding IRS e-file Signature Authorization Forms
  • Form 8802, Application for U.S. [...]

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Biden Spending Proposal Calls for 10% IRS Budget Increase

by , and | Apr 21, 2021 | , ,

The Biden Administration has requested a $1.2 billion increase in funding for the Internal Revenue Service (IRS) as part of its proposal for Fiscal Year 2022 (FY 2022) discretionary funding released in a letter from Office of Management and Budget Acting Director Shalanda Young on April 9, 2021. The additional funding would bring the IRS FY 2022 budget to $13.2 billion, which represents a 10.4% increase over the 2021 enacted budget.

The additional funding would be used to increase IRS enforcement, especially for oversight of high-income individuals and corporate tax returns to ensure compliance with existing tax laws. The discretionary request also seeks an additional $417 million to fund a multiyear tax enforcement initiative aimed at increasing tax compliance and revenues. In total, the discretionary request would increase resources for tax enforcement by nearly $1 billion. Other funds appropriated to the IRS would be used for development and improvement of online tools and better telephone and in-person customer service for taxpayers.

Apart from IRS spending, the discretionary spending proposal includes $191 million for the US Department of the Treasury’s Financial Crimes Enforcement Network to create a database that tracks the ownership and control of certain companies and organizations.

The discretionary spending proposal is intended as a starting point for congressional appropriators and will be followed by the president’s full budget proposal—including tax changes and pay-fors—later in the spring.

Practice Point: We believe that the US Congress is likely to appropriate additional funds for tax enforcement in the FY 2022 budget. Taxpayers should begin preparing for additional IRS audits and scrutiny of return positions. Such preparation may include examining prior tax return positions and ensuring they have audit-ready files.



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Finding John Doe: IRS Steps up Enforcement Efforts to Take the Anonymity Out of Virtual Currency

by | Apr 21, 2021 | , , ,

The Internal Revenue Service (IRS) is stepping up its virtual currency enforcement, and taxpayers who have engaged in a cryptocurrency transaction should immediately assess any potential tax implications as the IRS has recently issued two John Doe summonses to popular exchanges. These are the first it has issued in about three years, sending a very clear signal that the IRS is ready to tackle what it believes to be a continuing noncompliance. A US Federal District Court in Massachusetts upheld the summons issued to Circle Internet Financial Inc., including the popular cryptocurrency exchange Poloniex, while a US Federal Court for the Northern District of California required the government to submit a response explaining its need for the information requested in its summons to Kraken. (See: In re Tax Liability of John Does, No. 21-cv-2201, ECF No. 8 (N.D. Cal. Mar. 31, 2021)).

Filed on April 14, 2021, the government’s response provided numerous examples of how the data received in the Coinbase summons required additional requests in order for the exchange to locate actual taxpayers. The response argued that the need for multiple follow-ups defeated the purpose of the summons. It also described how information in Kraken’s possession, such as accountholder telephone numbers and email addresses, will facilitate the IRS’s ability to utilize relevant cryptocurrency platform data in its possession that was received from other sources relating to foreign-based cryptocurrency exchanges. Noting the potential for abuse by an accountholder, the response provided an example of an individual falsifying their identity as the basis for its need for complete account history in order to catch these issues. In addition, the response stated, “[m]atching the IP addresses for Kraken users to IP addresses and other data points in the IRS’s information will allow the IRS to link substantive account information from multiple sources for a single individual taxpayer and make a more accurate initial determination of whether that individual is in compliance with the internal revenue laws.”

It remains to be seen how the court will react to the government’s response. What is clear, though, from the response and the accompanying affidavit is that the IRS has made significant progress in its analysis of this data and its ability to follow leads. As a result, now is the time for individuals involved in these transactions to consult a tax professional to determine if they have any tax liability or potential exposure, including criminal exposure. After the Coinbase summons, the IRS issued 10,000 letters to taxpayers regarding virtual currency transactions. In the wake of these summonses, and potentially others, it is only a matter of time before the IRS reaches out to thousands of other taxpayers.

It is also clear that the enforcement arm of the IRS is working very closely with its counterparts around the world. The need for email addresses and phone numbers mentioned above to use foreign data certainly drives this point home. Even more so, as a precursor of things to [...]

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Weekly IRS Roundup April 12 – April 16, 2021

by | Apr 19, 2021 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 12, 2021 – April 16, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 12, 2021: The IRS issued proposed regulations setting forth requirements that certain foreign taxpayers must meet in order to obtain the benefits of investing in a qualified opportunity fund (QOF) under section 1400Z-2 of the Code. The proposed regulations also expand the flexibility of a disaster-related working capital safe harbor in the existing QOF regulations.

April 13, 2021: The IRS issued Notice 2021-24, extending previously announced relief from penalties for failure to make timely deposits of employment taxes. The Notice extends relief to apply to deposits reduced in anticipation of certain employment tax credits with respect to qualified leave wages and Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage premiums during 2021.

April 13, 2021: The IRS issued Notice 2021-27, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

April 13, 2021: The IRS issued a news release urging low and moderate income taxpayers to use IRS Free File to prepare and electronically file their tax returns.

April 14, 2021: The IRS issued Notice 2021-28, inviting the public to submit recommendations for items to be included on the 2021-2022 Priority Guidance Plan.

April 14, 2021: The IRS issued a news release announcing a fifth round of Economic Impact Payments consisting of over two million payments totaling over $3.4 billion, bringing the total amount of disbursements under the American Rescue Plan of 2021 to approximately 159 million payments worth more than $376 billion.

April 15, 2021: The IRS issued Revenue Ruling 2021-08, providing various prescribed interest rates for federal income tax purposes for May 2021.

April 15, 2021: The IRS issued a news release emphasizing that individuals experiencing homelessness may still qualify for tax benefits such as Economic Impact Payments and urged community groups and employers to share information and help such individuals file tax returns so that they can obtain such benefits.

April 16, 2021: 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 April 5 – April 9, 2021

by | Apr 13, 2021 | , ,

Presented below is our summary of significant Internal Revenue Serve (IRS) guidance and relevant tax matters for the week of April 5, 2021 – April 9, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 5, 2021: The IRS issued a news release announcing that it is mailing letters to certain taxpayers who claimed the 2020 Recovery Rebate Credit, explaining why they may be getting a different amount than expected.

April 5, 2021: The IRS issued a news release estimating that more than $1.3 billion of unclaimed income tax refunds are available to the estimated 1.3 million taxpayers who did not file a 2017 Form 1040 and reminding such taxpayers to file their 2017 returns before the May 17, 2021, deadline for claiming refunds.

April 7, 2021: The IRS issued a news release announcing a fourth round of Economic Impact Payments consisting of over 25 million payments totaling over $36 billion, bringing the total amount of disbursements under the American Rescue Plan of 2021 (ARPA) to more than 156 million payments worth approximately $372 billion.

April 8, 2021: The IRS issued Notice 2021-25 and an accompanying news release, providing guidance on the application of section 274(n)(2)(D) of the Code, a provision added by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 which provides for a temporary 100% deduction for food and beverages provided by a restaurant.

April 8, 2021: The IRS issued a news release reminding taxpayers who make estimated tax payments that the due date for the first estimated tax installment remains April 15, 2021.

April 8, 2021: The IRS issued a news release announcing various internal executive changes, including the appointment of Douglas O’Donnell as IRS Deputy Commissioner, Services and Enforcement, and Nikole Flax as Commissioner of the Large Business and International Division.

April 8, 2021: The IRS issued a news release reminding residents of US territories that, pursuant to recent legislation, they may be eligible to exclude up to $10,200 per person of unemployment compensation from gross income for the 2020 taxable year.

April 9, 2021: The IRS issued a news release announcing that, pursuant to ARPA, it was suspending the requirement that taxpayers repay excess advance payments of Premium Tax Credits.

April 9, 2021: The IRS issued a news release urging participants in abusive micro-captive insurance arrangements to exit the arrangements as soon as possible.

April 9, 2021: The IRS issued a news release reminding taxpayers that the deadline for filing the Report of Foreign Bank and Financial Accounts (FBAR) remains April 15, 2021.

April 9, 2021: 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, [...]

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Weekly IRS Roundup March 29 – April 2, 2021

by | Apr 6, 2021 | , ,

Presented below is our summary of significant Internal Revenue Serve (IRS) guidance and relevant tax matters for the week of March 29, 2021 – April 2, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 29, 2021: The IRS issued Notice 2021-21 and an accompanying news release, extending certain individual income tax deadlines to May 17, 2021, including the deadline for making contributions to individual retirement accounts (IRAs) and health savings accounts (HSAs) and the deadline for claiming refunds.

March 30, 2021: The IRS issued corrections to final regulations published on January 15, 2021, regarding credits for carbon capture equipment under section 45Q of the Code.

March 30, 2021: The IRS released Announcement 2021-6, providing a report on advance pricing agreements for calendar year 2020 under the Advance Pricing and Mutual Agreement Program.

March 30, 2021: The IRS issued a news release warning students and staff of educational institutions of an IRS-impersonation phishing scam.

March 30, 2021: The IRS issued a news release announcing that it anticipates Economic Impact Payments will begin to be issued to Social Security recipients and other individuals who do not normally file tax returns starting the weekend of April 3.

March 30, 2021: The IRS issued a news release providing answers to frequently asked questions regarding the reporting of pandemic-related emergency financial aid grants by students and higher education institutions.

March 31, 2021: The IRS issued a news release announcing that it will take steps to provide automatic refunds to taxpayers who filed tax returns reporting unemployment compensation prior to changes made by the American Rescue Plan Act of 2021 (ARPA).

April 1, 2021: The IRS issued a news release announcing a third round of Economic Impact Payments consisting of four million payments totaling over $10 billion, bringing the total amount of disbursements under ARPA to more than 130 million payments worth approximately $335 billion.

April 2, 2021: The IRS issued Notice 2021-23 and an accompanying news release, providing guidance on the changes made by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 on the employee retention credit under the Coronavirus Aid, Relief and Economic Security (CARES) Act.

April 2, 2021: The IRS issued a news release soliciting civic-minded volunteers to serve on the Taxpayer Advocacy Panel, a federal advisory committee for identifying taxpayer concerns and making recommendations for improving IRS service and customer satisfaction.

April 2, 2021: 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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