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required minimum distributions

IRS Roundup January 6 – 10, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio | Jan 22, 2025 | IRS Audits, 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 January 6, 2025 – January 10, 2025.

January 6, 2025: The IRS released Internal Revenue Bulletin 2025-2, which includes Announcement 2025-2. The announcement states that, if finalized, certain portions of proposed regulations on required minimum distributions under Section 401(a)(9) of the Internal Revenue Code (Code) will not apply before the 2026 distribution calendar year.

January 7, 2025: The IRS reminded taxpayers that final 2024 quarterly estimated tax payments are due January 15, 2025.

January 7, 2025: The IRS announced that the IRS Free File Guided Tax Software is now available through eight private-sector partners for taxpayers with adjusted gross income of $84,000 or less in 2024. One partner will offer a product in Spanish.

January 7, 2025: The IRS reminded taxpayers that IRS-certified volunteers are available to help qualified individuals file federal tax returns. Taxpayers can also sign up to volunteer with the Volunteer Income Tax Assistance or Tax Counseling for the Elderly programs.

January 8, 2025: National Taxpayer Advocate (NTA) Erin M. Collins released her 2024 Annual Report to Congress. The report identifies the 10 most serious problems involving taxpayers’ interactions with the IRS and makes administrative and legislative recommendations to address said problems. NTA Collins found overall improvement in the IRS’ service to taxpayers but also acknowledged persistent challenges, including delays in processing Employee Retention Credit claims and resolving Identity Theft Victim Assistance cases.

January 8, 2025: The IRS issued Revenue Ruling 2025-3, which addresses whether Section 530 of the Revenue Act of 1978, Pub. L. No. 95-600, as amended (Section 530) (addressing controversies involving whether individuals are employees for purposes of employment taxes), or the reduced rates of Code Section 3509 apply in five factual situations articulated in the ruling. The ruling also addresses whether the IRS will issue a notice of employment tax determination under Code Section 7436 in these same five situations.

The IRS also issued Revenue Procedure 2025-10 to provide updated guidance regarding the implementation of Section 530.

January 8, 2025: The IRS issued Revenue Procedure 2025-11, which provides the process under Code Section 48E(h) to apply for an allocation of capacity limitation as part of the Clean Electricity Low-Income Communities Bonus Credit Amount Program for 2025 and subsequent years. Receipt of an allocation increases the amount of the clean electricity investment credit determined under Section 48E(a) for the taxable year in which the applicable facility, with which the allocation of capacity limitation is associated, is placed in service. The revenue procedure provides guidance regarding the application process, including application review, documentation requirements, and placed in service reporting requirements. It also provides information on requirements specific to the Additional Selection Criteria application options, including documentation submission requirements, and describes how the capacity limitation will be divided across the facility categories.

January 10, 2025: The [...]

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Weekly IRS Roundup December 16 – December 20, 2024

by Kevin Spencer, Evan Walters and Samuel F. Hamer | Dec 31, 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 December 16 – 20, 2024.

December 16, 2024: The IRS released Internal Revenue Bulletin 2024-51, which includes the following:

Treasury Decision 10009, which provides guidance regarding the advanced manufacturing investment credit under § 48D of the Internal Revenue Code (Code). The guidance reflects changes made by the CHIPS Act of 2022. The § 48D credit may be claimed for qualified investments in an advanced manufacturing facility that engages in the manufacturing of semiconductors or semiconductor manufacturing equipment.
Treasury Decision 10010, which provides the rules for claiming the Advanced Manufacturing Production Credit under Code § 45X. The regulations describe the requirements for the production of eligible components, including the domestic production requirement. The regulations also provide rules regarding the sale of eligible components to unrelated persons, as well as rules that apply to sales between related persons. They include definitions of eligible components, rules related to calculating the credit, and specific recordkeeping and reporting requirements.
Treasury Decision 10014, which finalizes 2013 proposed regulations under Code § 752, which relates to a partner’s share of a partnership recourse liability. The final regulations adopt a proportionality rule in instances where more than one partner bears the economic risk of loss of the partnership recourse debt. The regulations also provide guidance regarding how partnership recourse debt should be allocated in tiered partnership structures, as well as guidance on the related-party rules. Interestingly, no new notice of proposed rulemaking or opportunity for public comment was provided regarding these regulations in the 11 years since the 2013 proposed regulations were issued.
Revenue Ruling 2024-27, which publishes the base period T-bill rate for the period ending September 30, 2024, pursuant to Code § 995(f). The rate for this period is 4.93%.

The IRS also released Notice 2025-1, which provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under § 417(e)(3), the 24-month average segment rates used under § 430(h)(2), the interest rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008, and the 30-year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I) of the Code.

The IRS also issued Revenue Ruling 2025-1, which provides the January 2025 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.

December 17, 2024: The IRS issued Revenue Procedure 2025-8, which modifies the procedures under Code § 446 and Treasury Regulation § 1.446-1(e) for obtaining automatic consent of the Commissioner of Internal Revenue (Commissioner) to change methods of accounting for expenditures paid or incurred in taxable years beginning after December 31, 2021, to comply with § 174 or to rely on interim guidance provided in Notice 2023-63, 2023-39 I.R.B. 919, as modified by Notice 2024-12, 2024-5 I.R.B. 616.

December 18, 2024: In Notice 2025-4 the [...]

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Weekly IRS Roundup July 15 – July 19, 2024

by Evan Walters, Kevin Spencer and Sama Kaseer | Jul 26, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15, 2024 – July 19, 2024.

July 15, 2024: The IRS released Internal Revenue Bulletin 2024-29, which includes:

Announcement 2024-29, which revokes the Internal Revenue Code (Code) 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

July 15, 2024: The IRS warned taxpayers about social media promotions of a non-existent “Self Employment Tax Credit” that are misleading individuals into improperly claiming the Paid Sick and Family Leave Credit that is intended for employees, not self-employed taxpayers.

July 16, 2024: The IRS released Revenue Ruling 2024-15, which provides the August 2024 applicable federal rates.

July 16, 2024: The IRS warned tax professionals about ongoing threats of phishing emails and cloud-based attacks aimed at stealing sensitive taxpayer information.

July 17, 2024: The IRS updated the Foreign Account Tax Compliance Act (FATCA) website to require users to establish multifactor authentication when registering to enhance identity verification. This change, effective as of July 14, 2024, mandates taxpayers to use IRS service providers Login.gov or ID.me to access their FATCA accounts.

July 19, 2024: The IRS released Notice 2024-59, which provides the 24-month average corporate bond segment rates for July 2024, yield curve and segment rates for single-employer plans, and 30-year Treasury securities interest rates.

July 19, 2024: The IRS issued proposed regulations and final regulations on the rules for required minimum distributions from retirement plans under Code § 401(a)(9). The final regulations largely adhere to the previously proposed rules, including the requirement for certain beneficiaries to continue receiving annual distributions until the end of the 10-year period, and will take effect on September 17, 2024.

July 19, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup May 6 – May 10, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | May 16, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6, 2024 – May 10, 2024.

May 6, 2024: The IRS released Internal Revenue Bulletin 2024-19, which includes the following:

Revenue Ruling 2024-09, which provides the May 2024 applicable federal rates.
Notice 2024-35, which provides guidance related to certain specified required minimum distributions for certain stock bonus, pension and profit-sharing plans described in Internal Revenue Code (Code) § 401(a). The notice also announces that the IRS intends to issue related final regulations that will apply for calendar years beginning on or after January 1, 2025.
Revenue Procedure 2024-20, which provides the domestic asset and liability percentages and domestic investment yields needed by foreign life insurance companies, foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Code § 842(b). The revenue procedure also provides instructions for computing foreign insurance companies’ estimated tax liabilities.
Treasury Decision 9990, which amends the definition of short-term, limited-duration insurance for purposes of exclusion from the definition of “individual health insurance coverage” under the Public Health Service Act and provides regulations regarding requirements for hospital indemnity or other fixed indemnity insurance to be considered an excepted benefit in the group and individual health insurance markets.
Revenue Procedure 2024-21, which provides issuers of qualified mortgage bonds (as defined in § 143(a)) and issuers of mortgage credit certificates (as defined in § 25(c)) with the nationwide average purchase price for residences located in the United States and the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia and US territories.
Announcement 2024-20, which revokes the § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

May 6, 2024: The IRS recognized two of its teams that reached the finals for the Samuel J. Heyman Service to America Medals as part of the 2024 Public Service Recognition Week. These teams included the Paperless Processing Initiative Team for its efforts to digitize IRS correspondence and two CI special agents for spearheading an investigation that led to a $3.4 billion cryptocurrency seizure and forfeiture.

May 6, 2024: The IRS reminded one million taxpayers who did not file their 2020 tax returns that they may still be eligible for a refund if they file by the May 17, 2024, deadline. The IRS estimates that more than $1 billion in refunds remain unclaimed as a result.

May 6, 2024: The IRS provided general tips for taxpayers upon receipt of mail from the IRS. In particular, taxpayers should remember to carefully read all IRS letters, save copies for their records and timely dispute notices where applicable.

May 6, 2024: The IRS
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