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Weekly IRS Roundup December 11 – December 15, 2023

by Evan Walters | Dec 20, 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 December 11, 2023 – December 15, 2023.

December 11, 2023: The IRS released Internal Revenue Bulletin 2023-50, which includes the following:

Proposed regulations that would update regulations under Internal Revenue Code (Code) §§ 267 and 707 to apply an entity approach to partnerships for purposes of applying loss limitation rules to related persons. The proposed regulations are intended to conform the existing regulations to current law. Comments and requests for a public hearing must be received by February 26, 2024.
Proposed regulations that relate to the calculation of foreign currency gains and losses under Code § 987. The proposed regulations include a current rate election, which would treat all balance sheet items as marked items and would require that income, gain, loss and deduction with respect to a qualified business unit be translated at a yearly average exchange rate. The proposed regulations also include an annual recognition election, which would trigger all items of income, gain, loss and deduction on an annual basis. Comments and requests for a public hearing must be received by February 12, 2024.

December 11, 2023: The IRS issued Notice 2023-80, which announces the intention to issue proposed regulations that address the application of the foreign tax credit (FTC) and dual consolidated losses in relation to the Global Anti-Base Erosion (GloBE) Model Rules. The notice also (i) extends the temporary relief period described in Notice 2023-55 for determining whether a foreign tax is eligible for an FTC pursuant to §§ 901 and 903 and (ii) addresses application of the temporary relief with respect to partnerships and their partners.

December 11, 2023: The IRS urged taxpayers to take certain important actions to help them file their 2023 federal income tax return for the upcoming filing season, including (i) making quarterly payments by January 16, 2024, if required, (ii) gathering 2023 tax documents, (iii) considering whether to file electronically and choosing direct deposit to expedite tax refunds, and (iv) reviewing energy-related credits. The IRS also reminded taxpayers that they can now view their IRS account transcripts online and should not rely on receiving refunds by a certain date.

December 13, 2023: The IRS announced plans for a new leadership structure at the agency that will feature a single deputy IRS Commissioner and four new IRS chief executive positions to cover taxpayer service, compliance, information technology and operations.

December 13, 2023: The IRS published Tax Tip 2023-126, which states that business taxpayers can electronically file any Form 1099 series information returns for free with the IRS Information Returns Intake System.

December 14, 2023: The US Department of the Treasury and the IRS issued proposed regulations on the § 45X advanced manufacturing production credit. The proposed [...]

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Weekly IRS Roundup September 6 – September 9, 2022

by McDermott Will & Emery | Sep 12, 2022 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 6, 2022 – September 9, 2022.

September 6, 2022: The IRS released Internal Revenue Bulletin 2022-36, which highlights the following:

Notice 2022-36: This guidance provides relief from certain failure to file penalties with respect to the 2019 and 2020 tax years. The IRS is refunding $1.2 billion in penalties for 1.6 million taxpayers, which will be waived, abated, refunded or credited. The relief is designed to help struggling taxpayers affected by the COVID-19 pandemic and to allow the IRS to focus resources on processing backlogged tax returns and taxpayer correspondence.

Notice 2022-35: This notice provides updates on the corporate bond monthly yield curve, the corresponding segment rates, the 24-month average corporate bond segment rates, the 25-year average segment rates and the 30-year Treasury securities interest rates.

Revenue Ruling 2022-17: This ruling provides the federal rates, adjusted federal rates, adjusted federal long-term rate and the long-term tax-exempt rate for September 2022.

September 6, 2022: The IRS reminded taxpayers who pay estimated taxes that the deadline to submit their third quarter payments is September 15, 2022. Taxpayers not subject to withholding may need to make quarterly estimated payments, including those who are self-employed, investors, or retirees or those with other income not subject to withholding, such as interest, dividends, capital gains, alimony, cryptocurrency and rental income.

September 6, 2022: The IRS released Tax Tip 2022-136, explaining common tricks and scams that lead to identity theft. The IRS also suggested a few steps to help protect data, which include:

Using multifactor authentication to protect client accounts
Allowing anti-virus software to update automatically
Using drive encryption and regularly backing up files to help stop theft and ransomware attacks.

September 7, 2022: The IRS is seeking comments on regulations that provide guidance on proving delivery for documents with a filing deadline, specifically in cases where there is no direct proof. The IRS is inviting comments on (1) whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (2) the accuracy of the agency’s estimate of the burden of the collection of information; (3) ways to enhance the quality, utility and clarity of the information collected; (4) ways to minimize the burden of the collection of information on respondents; and (5) estimates of capital or start-up costs and costs of operation, maintenance and purchase of services to provide information. The comment window closes on November 7, 2022.

September 7, 2022: The IRS released Tax Tip 2022-137, highlighting the work opportunity tax credit for businesses looking to hire help. The credit encourages employers to hire workers certified as members of any of the 10 groups identified as facing barriers [...]

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A 360-Degree View: November and December 2017

by McDermott Will & Emery | Dec 6, 2017 | Uncategorized

Wrapping Up November – and Looking Forward to December

Please view all of the topics we discussed over the last month, and take a look at the upcoming tax controversy events where our lawyers will be speaking in December.

Upcoming Tax Controversy Activities in December:

December 14, 2017: Catherine Battin, Britt Haxton, Kristen Hazel, Mary Kay Martire, Jane May, Sandra McGill and Judith Wethall will be hosting the Tax in the City® – A Year in Review event, which will focus on the state and local impact, as well as the federal and international aspects of tax reform.

December 14, 2017: Thomas Jones will be presenting the webinar, “Understand how the new Tax Reform bill will affect the status of captive insurers and hear the latest 2017 tax developments” for the Vermont Captive Insurance Association.