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Weekly IRS Roundup June 17 – June 21, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024.

June 17, 2024: The IRS released Internal Revenue Bulletin 2024-25, which includes the following:

  • Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.
  • Treasury Decision 9993, which provides final regulations on the election under Internal Revenue Code (Code) 6418 to transfer eligible energy credits, effective July 1, 2024.
  • Treasury Decision 9997, which reduces the cost of applying for or renewing a preparer tax identification number from $21 to $11.
  • Proposed Regulations, which would remove the “associated property rule” and related rules from the regulations on interest capitalization requirements for improvements to “designated property” under Code 263A(f) and clarify the definition of “improvement” in the existing regulations.

June 17, 2024: The IRS announced the establishment of a new dedicated group within the Office of Chief Counsel that will focus on developing guidance for partnerships, specifically with respect to the use of “basis shifting” transactions by related-party partnerships.

June 17, 2024: The IRS released guidance intended to target certain transactions that use the basis adjustment provisions in Code §§ 734, 743, 754 and 755 to shift basis to depreciable property through partnership transactions. This guidance includes:

  • Revenue Ruling 2024-14, which identifies three types of basis shifting transactions involving related parties that, according to the IRS, should be disallowed for lack of economic substance.
  • Notice 2024-54, which announces the IRS’s intent to propose regulations under Code §§ 732, 734, 743 and 755 that, if finalized, are intended to take effect on or after June 17, 2024. The regulations would identify several types of “covered transactions” in which basis step-ups resulting from partnership transactions would be disallowed. Unlike Revenue Ruling 2024-14, these regulations would not depend on a covered transaction lacking economic substance.
  • Proposed Regulation § 1.6011-18, which would identify certain partnership basis shifting transactions as “transactions of interest,” which generally must be disclosed to the IRS.

June 17, 2024: The IRS provided general tips for taxpayers benefiting from educational assistance programs under Code § 127 with respect to the treatment of certain educational expenses, qualified education loans and working condition fringe benefits.

June 17, 2024: The IRS released Notice 2024-53, which provides the 24-month average corporate bond segment rates for June 2024, yield curve and segment rates for single-employer plans and 30-year Treasury securities interest rates.

June 18, 2024: The IRS announced the release of final regulations for taxpayers who satisfy certain prevailing wage and apprenticeship (PWA) requirements regarding the construction, alteration or repair of certain clean energy facilities or properties, projects or equipment. Taxpayers who satisfy these PWA requirements are eligible for increased credit or deduction amounts for certain clean energy [...]

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Weekly IRS Roundup April 24 – April 28, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 – April 28, 2023.

April 24, 2023: The IRS released Internal Revenue Bulletin 2023-17, which highlights the following:

  • REG 121709-19: This document provides proposed regulations regarding supervisory approval of penalties. The purpose is to address the uncertainty surrounding various aspects of supervisory approval of penalties due to recent judicial decisions.
  • Announcement 2023-12: This announcement informs taxpayers and practitioners that the IRS has revised Form 3115, Application for Change in Accounting Method, and its instructions. This announcement also provides guidance to allow for a reasonable period for taxpayers to transition to the December 2022 Form 3115.
  • Announcement 2023-11: This announcement notifies the public that a proposed regulation identifies certain micro-captive transactions as “listed transactions” and certain other micro-captive transactions as “transactions of interest.”
  • Revenue Procedure 2023-12: This revenue procedure modifies specific language in Revenue Procedure 2023-5 to allow for the new electronic submission process of Form 8940, Request for Miscellaneous Determination. This revenue procedure also provides a 90-day transition relief period, during which paper Forms 8940 and letter applications will be accepted and processed by EO Determinations.
  • Notice 2023-30: This notice publishes the safe harbor deed language for extinguishment and boundary line adjustment clauses required by Section 605(d)(1). This notice also clarifies the process certain donors may use to amend an easement deed to substitute the safe harbor language for the corresponding language in the original deed.
  • Announcement 2023-07: This announcement informs federal civilian employees and other civilians who received certain reimbursement payments in 2022 and 2023 from the US Department of Defense for lodging, meals, and personal property damage expenses after the release of petroleum from the Red Hill Bulk Fuel Storage Facility on O‘ahu, Hawaii, that such payments are excludable from gross income for federal income tax purposes under Section 139.
  • REG 109309-22: These proposed regulations identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions and certain other micro-captive transactions as transactions of interest. The proposed regulations also provide guidance as to the reporting requirements for participants and material advisors to the transactions.

April 24, 2023: The IRS released Notice 2023-34, which provides that convertible virtual currency is treated as property for federal tax purposes and that general tax principles applicable to property transactions apply to transactions using convertible virtual currency. This notice modifies Notice 2014-21 by revising a sentence in the background section to remove the statement that virtual currency does not have legal tender status in any jurisdiction.

April 24, 2023: The IRS released Tax Tip 2023-55, reminding taxpayers that they don’t need to panic when they get a letter [...]

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