TAX CONTROVERSY 360
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
tax professionals
Subscribe to tax professionals's Posts

Weekly IRS Roundup February 13 – February 19, 2022

by | Feb 22, 2022 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2022 – February 19, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

February 14, 2022: The IRS issued a news release announcing the launch of a resource page that provides taxpayers with 2022 filing season updates, including updates concerning the resolution of unprocessed returns from the 2021 filing season.

February 15, 2022: The IRS issued Revenue Ruling 2022-4, providing various prescribed interest rates for federal income tax purposes for March 2022.

February 15, 2022: The IRS issued a news release announcing the release of an updated Form 14457, which relates to the IRS Voluntary Disclosure Practice for criminal prosecution. The updates include an expanded section on the reporting of virtual currency.

February 15, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the tax treatment of emergency grants for higher education, which were introduced pursuant to pandemic-related legislation.

February 16, 2022: The IRS issued a news release recommending that taxpayers use the online resources on its homepage as their first resource for tax inquiries and provided links to certain commonly used resources.

February 16, 2022: The IRS issued a news release, warning tax professionals to be alert for a new phishing scam designed to steal tax preparation software account credentials.

February 16, 2022: The IRS issued a news release, soliciting applications for Taxpayer Advocacy Panel membership, an advisory body that receives taxpayer feedback and makes suggestions for improving IRS customer service.

February 16, 2022: The IRS issued a news release, setting forth additional transition relief (in the form of an additional exception for certain taxpayers for tax year 2021) from the requirement to file the new Schedules K-2 and K-3 relating to partnerships and flow-through entities.

February 17, 2022: The IRS issued Notice 2022-09, providing the monthly update to certain interest rates used for pension plan funding and distribution purposes.

February 17, 2022: The IRS issued a news release, reminding taxpayers with income from a farming or fishing business to file returns and pay taxes that are due by March 1, 2022, unless they have made estimated tax payments.

February 17, 2022: The IRS issued a news release, providing an update to a Fact Sheet containing answers to frequently asked questions regarding the 2021 Recovery Rebate Credit, enacted as part of the American Rescue Plan Act of 2021 (ARPA).

February 18, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special [...]

Continue Reading



read more

Weekly IRS Roundup November 29 – December 3, 2021

by | Dec 6, 2021 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 29, 2021 – December 3, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 29, 2021: The IRS published a news release warning taxpayers and tax professionals to beware of a dangerous combination of events that can increase their exposure to tax scams and identity theft. The IRS stated that the holiday shopping season, the upcoming tax season and the pandemic all create additional opportunities for criminals to steal sensitive personal or finance information.

November 30, 2021: The IRS issued Revenue Procedure 2021-53, which provides temporary guidance regarding the treatment of certain stock distributions by publicly offered real estate investment trusts and publicly offered regulated investment companies in recognition of the need for liquidity as a result of COVID-19. The guidance reduces the minimum required aggregate amount of cash that distributee shareholders may receive to no less than 10% of the total distribution in order for Section 301 (by reason of Section 305(b)) to apply to such distribution.

November 30, 2021: The IRS published a news release warning taxpayers to be wary of fake charities used by scammers to trick unsuspecting donors into providing money and sensitive financial and personal information.

November 30, 2021: The IRS posted an issue snapshot concerning issue indicators and audit tips for public and tax-exempt employer contributions to eligible deferred compensation plans (as defined in Section 457(b)).

December 1, 2021: The US Competent Authority posted the arrangement between Competent Authorities of the United States and Turkey, setting forth parameters on the exchange of county-by-country reporting agreements to combat transfer pricing, base erosion and profit shifting-related risks.

December 1, 2021: The IRS published a news release reminding taxpayers they can get extra protection starting in January by joining its Identity Protection Personal Identification Number (IP PIN) program. Anyone who can verify their identity can protect themselves against tax-related identity theft by opting into the program.

December 2, 2021: The IRS published a news release warning tax professionals that they face additional security risks from cybercriminals seeking to use the pandemic and phishing scams to steal sensitive client information.

December 2, 2021: The IRS recommended nonacquiescence in Mayo Clinic v. United States, 997 F.3d 789 (8th Cir. May 13, 2021), rev’g 412 F. Supp. 3d 1038 (D. Minn. 2019), where the appeals court invalidated Treasury Regulations Section 1.170A-9(c)(1)’s requirement that the primary function of an educational organization described in Section 170(b)(1)(A)(ii) be the presentation of formal instruction. For more background, see our recent post.

December 2, 2021: The IRS published a news release reminding tax professionals and taxpayers that they can use digital signatures on a variety of common IRS forms and access a [...]

Continue Reading



read more

Weekly IRS Roundup November 15 – November 19, 2021

by | Nov 24, 2021 | , ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 15, 2021 – November 19, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

November 15, 2021: The IRS published a news release announcing the launch of a new online tool designed to help US withholding agents comply with their reporting and withholding responsibilities with respect to IRS Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding. The tool performs a quality review of data before submitting to the IRS. Use of the tool does not change a withholding agent’s obligations to file Form 1042-S with the IRS and furnish a copy to the payee.

November 15, 2021: The IRS published a news release announcing that victims of wildfires that began July 14, 2021, now have until January 3, 2022, to file various individual and business tax returns and make tax payments.

November 16, 2021: The IRS published a news release announcing that, effective November 15, 2021, tax professionals are able to order up to 30 Transcript Delivery System transcripts per client through the Practitioner Priority Service line. This is an increase from the previous 10 transcripts per client limit.

November 16, 2021: The IRS published a news release regarding Notice 2021-63, which details how the temporary 100% business deduction for food or beverages from restaurants applies to taxpayers properly applying the rules of Revenue Procedure 2019-48 when using per diem rates.

November 17, 2021: The IRS published a news release announcing that victims of Hurricane Ida throughout Mississippi now have additional time—until January 3, 2022—to file various individual and business tax returns and make tax payments.

November 17, 2021: The Internal Revenue Service Advisory Council (IRSAC) published a news release announcing its annual report for 2021, which includes recommendations to the IRS regarding new and continuing issues in tax administration. The 2021 report includes recommendations on 24 issues, covering a broad range of topics. The IRSAC is a federal advisory committee that provides an organized public forum for the discussion of relevant tax administration issues between IRS officials and representatives of the public. IRSAC members offer constructive observations regarding current or proposed IRS policies, programs and procedures.

November 17, 2021: The IRS published a news release announcing it unveiled a new how-to video series enabling taxpayers to avoid potential scams by considering and applying for an Offer in Compromise themselves and to avoid paying excessive fees to companies advertising outlandish claims.

November 17, 2021: The IRS published a news release announcing the launch of an improved identity verification and sign-in process that enables more people to securely access IRS online tools and applications.

November 17, 2021: The IRS’s National Taxpayer Advocate published a blog post indicating that US Congress [...]

Continue Reading



read more

Weekly IRS Roundup August 16 – August 20, 2021

by | Aug 24, 2021 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 16, 2021 – August 20, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 17, 2021: The IRS Security Summit series, in partnership with state tax agencies and the tax industry, is focusing on teaching tax professionals the warning signs to look for regarding identity theft and pandemic-related phishing scams.

August 20, 2021: The IRS launched a new feature allowing any family receiving monthly Child Tax Credit payments to quickly and easily update their mailing address using a new portal on IRS.gov. The deadline for changing a mailing address for a September check is August 30, 2021, at 12:00 am EDT.

August 20, 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 Emily Mussio in our Chicago office for this week’s roundup.



read more

Weekly IRS Roundup August 9 – August 13, 2021

by | Aug 16, 2021 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 9, 2021 – August 13, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

August 10, 2021: The IRS issued Revenue Procedure 2021-33 and an accompanying news release, providing a safe harbor pursuant to which employers are permitted to exclude certain amounts from gross receipts for purposes of determining Employee Retention Credit eligibility.

August 10, 2021: The IRS issued Notice 2021-43 and an accompanying news release, providing relief for employers to claim the Work Opportunity Tax Credit under Section 51 of the Code with respect to employees who began work after December 31, 2020. This latest update is in response to the extension of the associated Empowerment Zone designations through December 31, 2025, and pursuant to the Taxpayer Certainty and Disaster Tax Relief Act of 2020.

August 10, 2021: The IRS issued a news release as part of a Security Summit series in partnership with state tax agencies and the tax industry, advising tax professionals to guard against pandemic-related phishing scams.

August 11, 2021: The IRS issued Revenue Procedure 2021-34, updating and modifying procedures for taxpayers to obtain automatic consent for certain income tax accounting method changes made to comply with Section 451 of the Code, as amended by the Tax Cuts and Jobs Act (TCJA).

August 11, 2021: The IRS issued Revenue Procedure 2021-35, modifying procedures for the safe harbor method of accounting for original issue discounts on a pool of credit card receivables in response to changes made to Section 451 by the TCJA.

August 13, 2021: The IRS issued Announcement 2021-13, announcing that the United States and United Kingdom have entered into an arrangement providing that references to the North American Free Trade Agreement (NAFTA) in the US-UK income tax treaty are to be interpreted as references to the United States-Mexico-Canada Agreement (USMCA) upon the USMCA’s entry into force.

August 13, 2021: The IRS issued Announcement 2021-14, announcing that the United States and United Kingdom have entered into an arrangement providing that, notwithstanding the United Kingdom’s withdrawal from the European Union, UK residents will continue to be treated as “equivalent beneficiaries” for purposes of applying the derivative benefits test to trusts under the Limitation on Benefits provision of the US-UK income tax treaty.

August 13, 2021: The IRS issued a news release announcing the disbursement of the August round of advance payments of the Child Tax Credit, consisting of approximately 36 million payments worth approximately $15 billion.

August 13, 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 [...]

Continue Reading



read more

Weekly IRS Roundup July 26 – July 30, 2021

by | Aug 2, 2021 | , ,

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

July 26, 2021: The IRS issued Notice 2021-46 as a supplement to Notice 2021-31 issued in May, providing additional guidance on the temporary premium assistance for Consolidated Omnibus Budget Reconciliation Act (COBRA) health insurance benefits and the associated COBRA premium assistance credit—enacted by the American Rescue Plan Act of 2021 (ARPA).

July 27, 2021: The IRS issued a news release urging tax professionals to raise awareness amongst clients about the availability of Identity Protection PINs, a tax return security feature designed to protect against tax-related identity theft.

July 28, 2021: The IRS issued a news release announcing the imminent issuance of another round of tax refunds to those who paid taxes on unemployment compensation in 2020, pursuant to the retroactive exclusion of such compensation from 2020 taxable income under ARPA. The refunds will be issued to approximately 1.5 million taxpayers, averaging more than $1,600.

July 29, 2021: The IRS issued a news release announcing an update to previously-released FAQs regarding paid sick and family leave tax credits under ARPA.

July 30, 2021: The IRS issued Notice 2021-45, providing a list of counties and parishes that constitute as qualified disaster zones for purposes of determining low-income housing tax credits under section 42 of the Code, as expanded by the Taxpayer Certainty and Disaster Tax Relief Act of 2020.

July 30, 2021: The IRS issued Notice 2021-48, providing guidance on changes made under ARPA to the funding rules for single-employer defined benefit pension plans.

July 30, 2021: The IRS issued Announcement 2021-12, revealing recent disciplinary sanctions imposed on certain tax practitioners pursuant to the Circular 230 rules for practice before the IRS.

July 30, 2021: The IRS issued a news release announcing the awarding of a $100,000 Low Income Taxpayer Clinic grant to West Virginia University College of Law to assist the university in providing tax controversy litigation services to low-income and English as a second language (ESL) taxpayers.

July 30, 2021: The IRS issued a news release reminding taxpayers who hold Employer Identification Numbers (EINs) of their responsibility to file Form 8822-B, updating their information with the IRS upon a change of responsible party or contact information.

July 30, 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.



read more

Weekly IRS Roundup July 19 – July 23, 2021

by | Jul 26, 2021 | ,

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

July 19, 2021: The IRS issued a news release announcing an enhancement to its online account systems, specifically that tax professionals and taxpayers may now initiate and execute a Power of Attorney or Tax Information Authorization online in lieu of using Forms 2848 and 8821, respectively.

July 20, 2021: The IRS issued a news release urging tax professionals to use multi-factor authentication technology to protect taxpayers’ information from identity and data theft.

July 21, 2021: The IRS issued proposed regulations expanding electronic filing requirements with respect to various business tax returns and statements, pursuant to the Taxpayer First Act of 2019 provisions and related legislation.

July 21, 2021: The IRS issued a news release announcing that, in partnership with local civic organizations, events will be held in several cities across the country on July 23 – 24, 2021, to assist eligible families in registering for advance payments of the Child Tax Credit.

July 21, 2021: The IRS issued a news release announcing the disbursement of more than 2.2 million Economic Impact Payments worth more than $4 billion, bringing the total amount of disbursements under the American Rescue Plan Act of 2021 to more than 171 million payments worth more than $400 billion.

July 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.



read more

Weekly IRS Roundup July 5 – July 9, 2021

by | Jul 12, 2021 | ,

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

July 6, 2021: The IRS—in conjunction with the US Department of Labor and the US Department of Health and Human Services—released temporary regulations implementing provisions of the No Surprises Act, enacted as part of the Consolidated Appropriations Act, 2021 and designed to protect persons with health insurance from “surprise” medical bills for certain medical services. The IRS separately released proposed regulations with respect to a subset of the temporary regulations, containing the same text.

July 6, 2021: The IRS issued a set of FAQs and an associated news release, answering questions regarding COVID-related grants provided to certain transportation companies under the Coronavirus Economic Relief for Transportation Services (CERTS) Act.

July 7, 2021: The IRS issued a news release reminding taxpayers that, in partnership with local civic organizations, special events will be held in 12 cities on July 9 – 10, 2021, to assist eligible families in registering for advance payments of the Child Tax Credit.

July 9, 2021: The IRS issued Notice 2021-38 and an accompanying news release, providing guidance regarding the requirements (as enacted under section 432(k) of the Code as part of the American Rescue Plan Act of 2021) for certain multiemployer pension plans to obtain special financial assistance under section 4262 of the Employee Retirement Income Security Act of 1974 (ERISA), as enacted by the same Act.

July 9, 2021: The IRS issued a news release announcing that July 13, 2021, is the final day to register for the 2021 IRS Nationwide Tax Forum, an annual series of continuing education seminars for tax professionals to be held virtually from July 20, 2021 through August 19, 2021.

July 9, 2021: The IRS issued a news release reminding taxpayers of the resources available on irs.gov to assist with answering tax questions.

July 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, office for this week’s roundup.



read more

IRS Issues Annual “Dirty Dozen” List of Tax-Related Scams

by , and | Jul 1, 2021 |

Each year, the Internal Revenue Service (IRS) publishes a list of tax-related scams, which it calls the “Dirty Dozen.” This year, it provided a “Dirty Dozen” scam series warning taxpayers of such scams.

In IR-2021-135 (June 28, 2021), the IRS rolled out its “Dirty Dozen” list for 2021, warning taxpayers to look out for 12 nefarious schemes and scams. The 2021 list is separated into the following four categories:

  • Pandemic-related scams, such as Economic Impact Payment theft
  • Personal information cons including phishing, ransomware and phone “vishing”
  • Ruses focusing on unsuspecting victims, such as fake charities and senior/immigrant fraud
  • Schemes that persuade taxpayers into unscrupulous actions, such as Offer In Compromise mills and syndicated conservation easements

In IR-2021-137 (June 29, 2021), the IRS advised taxpayers to look out for unexpected schemes in the form of emails, texts, social media messages and phone calls. These phishing scams target taxpayers and tax professionals and can seem legitimate at first glance. For example, emails or phone calls purporting to be from the IRS may request financial information or request that the recipient link to an attachment. Some scams utilize social media and seek to use events like COVID-19 to trick people. Recipients of such unsolicited emails or phone calls can report the actions to the Treasury Inspector General for Tax Administration (TIGTA).

In IR-2021-141 (June 30, 2021), the IRS shared five scams relating to requests for donations to fake charities, tax scams targeting immigrants and senior citizens, offer in compromise mills, unscrupulous tax return preparers and unemployment insurance fraud.

In IR- 2021-144 (July 1, 2021), the IRS concluded its series by warning taxpayers to watch out for certain transactions and arrangements marketed by promoters.

Prior year information on the “Dirty Dozen” lists can be found here.

Practice Point: Taxpayers and tax professionals need to be vigilant in protecting against tax-related scams and schemes. If you doubt the legitimacy of a contact purporting to be from the IRS, make sure to confirm the identity of the contact with IRS personnel. For example, we recently received an unsolicited email from an irs.gov address and, to ensure the email was legitimate, we reached out to IRS personnel and were able to confirm that the email was legitimate. However, we have had other situations where emails and phone calls purporting to be from the IRS were from third parties with no connection to the government.



read more

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., [...]

Continue Reading



read more

BLOG EDITORS

Kevin Spencer

Evan Walters

STAY CONNECTED

Subscribe

TOPICS

ARCHIVES

jd supra readers choice top firm 2023 badge

Legal Notices  |  Privacy & Cookies Policy

Attorney Advertising © 2024 McDermott Will & Emery

Contact Us: info@mwe.com

Attorney Advertising ©2020 McDermott Will & Emery