Technical Advice Memorandums 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 November 27 – December 1, 2023

by Kevin Spencer | Dec 7, 2023 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 27, 2023 – December 1, 2023.

November 27, 2023: The IRS released Internal Revenue Bulletin 2023-48, which includes Revenue Procedure 2023-34 and sets forth the annual inflation adjustments for various Internal Revenue Code provisions for tax year 2024. Also included are the tax rate schedules and other tax changes.

November 27, 2023: The IRS and Security Summit partners launched the eighth National Tax Security Awareness Week along with tips for taxpayers and tax professionals to avoid scams and protect sensitive personal information ahead of the upcoming 2024 filing season and throughout the year.

November 27, 2023: The IRS published Tax Tip 2023-124, which reminds taxpayers that the IRS has newsletters for a variety of tax topics and audiences.

November 27, 2023: The IRS published proposed regulations that would amend the rules applicable to plans that include cash or deferred arrangements under § 401(k) to provide guidance for long-term, part-time employees. Comments and requests for a public hearing must be received by January 26, 2024.

November 27, 2023: The IRS published proposed regulations that would update current regulations regarding whether certain persons are treated as related persons who are subject to certain special rules pertaining to transactions with partnerships. The proposed regulations would affect partnerships that enter into transactions with related persons that result in a gain or loss on a sale or exchange of property or result in a difference in the timing recognition of income and deductions on account of the persons’ different methods of accounting. Comments and requests for a public hearing must be received by February 26, 2024.

November 28, 2023: The IRS reminded tax professionals to protect themselves and their clients’ sensitive information, including by putting written security plans in place and by following new requirements to use multifactor authentication.

November 28, 2023: The IRS highlighted its continued support of international efforts to fight fraud and charity scams in light of Charity Fraud Awareness Week.

November 28, 2023: The IRS published Tax Tip 2023-125, which reminds paid tax return preparers to renew their Preparer Tax Identification Number via the online renewal process before it expires on December 31, 2023.

November 29, 2023: The IRS reminded taxpayers that they can get extra protection against identity theft during the 2024 tax season by joining the Identity Protection Personal Identification Number program.

November 30, 2023: The IRS urged businesses to remain vigilant against cyberattacks aimed at stealing their customers’ personal information and other business data.

December 1, 2023: The US Department of the Treasury and the IRS issued two guidances on the § 30D clean vehicle credit excluded entity restriction, as amended by the Inflation Reduction Act [...]

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Weekly IRS Roundup May 18 – May 22, 2020

by McDermott Will & Emery | May 26, 2020 | IRS Appeals, IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 18 – May 22, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

May 18, 2020: The U.S. Tax Court announced that comments to the proposed amendments to the Rules of its Practice and Procedure should be emailed to Stephanie A. Servoss, Clerk of the Court, at Rules@ustaxcourt.gov. The Tax Court has not received mail since March 19, 2020.

May 18, 2020: The IRS added approximately 3,500 phone operators to answer Economic Impact Payment (EIP) questions.

May 19, 2020: The Large Business & International (LB&I) released information regarding the Swiss Bank Program Campaign. The program allows Swiss financial institutions to provide information on the U.S. persons with beneficial ownership of foreign financial accounts. The campaign will address noncompliance of such taxpayers.

May 20, 2020: The IRS announced that Andy Keyso has been selected to serve as the Chief of the IRS Independent Office of Appeals, the IRS announced. For more information on Mr. Keyso and IRS Appeals, see our write-up here.

May 21, 2020: The IRS announced that the 2020 IRS Nationwide Tax Forums will be held virtually in 2020 with a series of live-streamed webinars beginning this July. The 2020 Nationwide Tax Forums will begin on July 21 and continue through August 20.

May 22, 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.