syndicated conservation easements Archives

Weekly IRS Roundup June 24 – June 28, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Jul 2, 2024 | 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 June 24, 2024 – June 28, 2024.

June 24, 2024: The IRS released Internal Revenue Bulletin 2024-26, which includes the following:

Notice 2024-45, which provides the inflation adjustment factors and applicable amounts for the credit for Clean Hydrogen Production Tax Credit under § 45V of the Internal Revenue Code (Code) for calendar years 2023 and 2024.
Notice 2024-46, which provides that payments made by Norfolk Southern to individuals affected by the 2023 train derailment incident in East Palestine, Ohio, are considered “qualified disaster relief payments” under Code § 139, which should be excluded from gross income if they are not otherwise covered by insurance.
Notice 2024-50, which adds polyoxymethylene to the list of “taxable substances” subject to an excise tax under Code § 4672(a). The effective date of this modification for purposes of Code § 4662(e) refund claims is July 1, 2022.
Notice 2024-51, which provides the 2023 reference price under Code § 45K(d)(2)(C), applicable in determining the credit amounts provided under Code § 43 and § 45I and that percentage depletion for oil and natural gas produced from marginal properties and oil credits under Code § 613A.

June 25, 2024: The IRS apologized to hedge fund manager Ken Griffith and other taxpayers affected by the tax data leak perpetrated by former IRS contractor Charles Littlejohn.

June 26, 2024: The IRS highlighted challenges it encountered during the 2024 filing season and objectives for the upcoming fiscal year in a semi-annual report to Congress. Among other issues, the IRS identified delays in issuing refunds to identity theft victims, misleading telephone measures that lead to poor resource allocation decisions, and delays in processing Employee Retention Credit claims as key taxpayer challenges.

June 26, 2024: The IRS announced it will mail time-limited settlement offers in July 2024 to eligible taxpayers who participated in Syndicated Conservation Easements and substantially similar transactions that are under audit. The settlement offer will require substantial concession of income tax benefits and the application of penalties.

June 26, 2024: The IRS, through its Electronic Tax Administration Advisory Committee, released its 2024 annual report, which contains a total of 12 recommendations for Congress and the IRS to help improve tax administration.

June 27, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Mississippi that were affected by severe weather since April 8, 2024. The new deadline is November 1, 2024. 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 Hancock, Hinds, Humphreys, Madison, Neshoba and Scott counties.

June 28, 2024: The [...]

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Weekly IRS Roundup September 28 – October 2, 2020

by McDermott Will & Emery | Oct 7, 2020 | IRS Guidance, Settlements, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

September 29, 2020: The IRS published final regulations related to the source of income for certain property sales and modifying rules for determining whether foreign source income is effectively connected with a US trade or business.

September 29, 2020: The IRS published final regulations related to a wide range of foreign tax credit topics. The regulations provide guidance on the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments and the treatment of certain payments under the global intangible low-taxed income provisions.

October 1, 2020: The IRS published Notice 2020-70 generally removing Form 1040NR, US Nonresident Alien Income Tax Return, from the list of returns that are administratively exempt from the electronic filing requirement.

October 1, 2020: The IRS published final regulations related to savings programs for eligible individuals with a disability under section 529A.

October 1, 2020: The IRS released an Office of Chief Counsel Notice related to settlement options for syndicated conservation easement transactions.

October 2, 2020: The IRS published Notice 2020-76 providing for transition relief related to information reporting requirements related to the Affordable Care Act.

October 2, 2020: The IRS updated the instructions for Form 8858: Information Return of US Persons with Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs) to reflect changes due to the COVID-19 pandemic.

October 2, 2020: The IRS released Internal Revenue Bulletin 2020-41, dated October 5, 2020, containing the following highlights: Announcement 2020-12 (Administrative); Rev. Proc. 2020-42 (Administrative); Rev. Rul. 2020-20 (Income Tax); Rev. Rul. 2020-21 (Income Tax); TD 9915 (Income Tax); Notice 2020-73 (Income Tax); Notice 2020-74 (Income Tax).

September 25, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.

Weekly IRS Roundup June 22 – June 26, 2020

by McDermott Will & Emery | Jun 29, 2020 | Court Procedure Matters, IRS Guidance, Settlements, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 22 – June 26, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

June 24, 2020: The IRS issued final regulations permitting a regulated investment company (RIC) that receives qualified real estate investment trust (REIT) dividends to report dividends the RIC pays to its shareholders as section 199A dividends.

June 25, 2020: The IRS Office of Chief Counsel announced a limited settlement offer to certain taxpayers with pending docketed US Tax Court cases involving syndicated conservation easement transactions. The settlement offer requires a concession of the income tax benefits claimed by the taxpayer and imposes penalties.

June 26, 2020: The IRS will begin to reopen Taxpayer Assistance Centers starting on June 29, 2020. In-person appointments will be available for certain items.

June 26, 2020: The IRS issued a reminder to taxpayers and businesses that income tax liabilities as well as postponed April 15 and June 15, 2020, estimated tax payments are due July 15, 2020. Taxpayers who owe a 2019 income tax liability, as well as estimated tax for 2020, must make two separate payments on or by July 15, 2020. One payment should be for their 2019 income tax liability and one payment for their 2020 estimated tax payments.

June 26, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Emily Mussio in our Chicago office for this week’s roundup.

Weekly IRS Roundup June 24 – June 28, 2024

Weekly IRS Roundup September 28 – October 2, 2020

Weekly IRS Roundup June 22 – June 26, 2020

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