semiconductors Archives - TAX CONTROVERSY 360

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 June 12 – June 16, 2023

by Sarah M. Raben | Jun 20, 2023 | IRS Appeals, IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 12, 2023 – June 16, 2023.

June 12, 2023: The IRS released Internal Revenue Bulletin 2023-24, which highlights the following:

Notice 2023-43: This notice provides guidance with respect to Section 305 of the SECURE 2.0 Act of 2022. Section 305 provides for the expansion of the Employee Plans Compliance Resolution System currently set forth in Revenue Procedure 2021-30. This notice provides interim guidance in advance of any updates to Revenue Procedure 2021-31 and is not intended to be comprehensive.

June 12, 2023: The IRS announced a new series of special events at this year’s IRS Nationwide Tax Forums, including sessions focused on practice management, the taxpayer experience, cybersecurity and a town hall meeting with the National Taxpayer Advocate.

June 12, 2023: The IRS released Tax Tip 2023-79, reminding taxpayers that when they disagree with an IRS decision, they can submit a written request to have the IRS Independent Office of Appeals (IRS Appeals) review the decision.

June 13, 2023: The IRS announced that IRS Commissioner Danny Werfel will deliver the keynote speech at the Nationwide Tax Forum in Atlanta on July 25 to July 27. The three-day session will provide tax professionals with multiple opportunities to learn more about tax law changes and IRS transformation efforts.

June 13, 2023: The IRS released Tax Tip 2023-80, reminding taxpayers that they may be able to avoid the time and expense of a court trial by asking IRS Appeals to review their case if they disagree with an IRS decision. When IRS Appeals officers review cases submitted by taxpayers, they meet informally and consider both the taxpayers’ and the IRS’s position.

June 14, 2023: The IRS announced proposed regulations and frequently asked questions that describe rules for entities that earn certain clean energy credits and choose to make an elective payment election and rules for eligible taxpayers who elect to transfer certain credits to unrelated parties. For tax years beginning after December 31, 2022, certain eligible taxpayers can elect to transfer all or a portion of eligible tax credits to unrelated taxpayers in exchange for cash payments.

June 14, 2023: The IRS issued proposed regulations that provide guidance on the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, which was established by the Creating Helpful Incentives to Produce Semiconductors Act of 2022. This credit incentivizes the manufacture of semiconductors and semiconductor manufacturing equipment within the United States.

June 14, 2023: The IRS released Tax Tip 2023-81, reminding taxpayers to think about various tax considerations when selling their home. For example, they may qualify to exclude all or part of any capital gain from the sale of their home, [...]

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Weekly IRS Roundup March 20 – March 24, 2023

by Sarah M. Raben | Mar 27, 2023 | 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 20, 2023 – March 24, 2023.

March 20, 2023: The IRS released Internal Revenue Bulletin 2023-12, which highlights the following:

Notice 2023-22: This notice advises state and local housing credit agencies that allocate low-income housing tax credits under Section 42, as well as states and other issuers of tax-exempt private activity bonds under Section 141, of the population figures to use in calculating the (1) state housing credit ceiling under Section 42(h), (2) private activity bond volume cap under Section 146 and (3) private activity bond volume limit under Section 142(k).

March 20, 2023: The IRS announced tips to avoid processing delays and refund adjustments as the April 18, filing deadline approaches. The tips include gathering all tax documents, filing electronically, using the correct filing status, double-checking names and social security numbers, answering the digital assets question and reporting all taxable income.

March 20, 2023: The IRS announced a new entry into the annual Dirty Dozen list of tax scams: promoter claims involving the Employee Retention Credit (ERC). Some third parties continue to widely advertise services that target taxpayers who may not be eligible for the ERC. The advertisements, along with the increased prevalence of websites touting how easy it is to qualify for the ERC, suggest that the abusive claims may be legitimate. The annual list of schemes is aimed at raising awareness of aggressive promoters and con artists. These schemes put people at financial risk and increase the chances of identity theft.

March 20, 2023: The IRS released Tax Tip 2023-35, providing options for taxpayers who cannot pay their tax bill by April 18. The IRS also reminded taxpayers to still file their tax returns even if they cannot pay to avoid a failure-to-file penalty.

March 21, 2023: The IRS announced that it is requesting feedback regarding the tax treatment of a non-fungible token (NFT) as a collectible under the tax law in Notice 2023-27. An NFT is a unique digital identifier that is recorded using distributed ledger technology and may be used to certify the authenticity and ownership of an associated right or asset. The guidance also requests comments on the treatment of NFTs as collectibles and describes how the IRS intends to determine whether an NFT is a collectible until further guidance is issued.

March 21, 2023: The IRS issued proposed regulations that provide guidance on the implementation of the Advanced Manufacturing Investment Credit, established by the Creating Helpful Incentives to Produce Semiconductors Act of 2022 (CHIPS Act). The credit incentivizes the manufacture of semiconductors and semiconductor manufacturing equipment within the United States.

March 21, 2023: The IRS cautioned taxpayers to watch out for scammers using email and text messages to [...]

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Weekly IRS Roundup December 16 – December 20, 2024

Weekly IRS Roundup June 12 – June 16, 2023

Weekly IRS Roundup March 20 – March 24, 2023

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