The IRS issued final regulations providing rules for how to determine gain or loss when property subject to depreciation is disposed of, how to determine the asset disposed of, and how to account for partial dispositions of depreciated property.
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Whistleblower Final Rules Expand Definition of Collected Proceeds
Comprehensive final regulations provide rules for whistleblower awards under Secs. 7623(a) and (b), as well as rules governing the disclosure of return information under Sec. 6103(h) to pursue these claims.
Regulations Provide Guidance on Sec. 6707 Material Adviser Penalty
The IRS issued final regulations under Sec. 6707, which imposes a large penalty on any material adviser who fails to file a return required under Sec. 6111(a) disclosing a reportable transaction or who files a false or incomplete return.
IRS Issues Guidance on Health Insurance Premium Tax Credits
The IRS issued regulations and revenue procedures addressing how to calculate the Sec. 36B premium tax credit.
New IRS Rules Simplify Compliance for Money Market Fund Shares
The IRS issued guidance that allows a simplified method for calculating gain or loss on shares in MMFs subject to the new rules and exempts redemptions of shares in these MMFs from the wash sale rules
Federal Courts Disagree on Health Care Credits for Federal Exchanges
Two federal appellate courts issued conflicting decisions regarding the availability of the Sec. 36B premium tax credit for taxpayers who purchase health insurance on exchanges set up by the federal government.
Final Rules Issued on Bona Fide Indebtedness and Terminating Partnership’s Startup Expenses
Final regulations were issued on S corporation shareholder basis of indebtedness of the S corporation to the shareholder only if the indebtedness is bona fide and on the deductibility of startup expenditures and organizational expenses for partnerships following a termination of a partnership.
New Rules on Covered Asset Acquisitions Will Shut Down Transactions to Avoid Sec. 901(m)
The IRS will issue regulations to prevent taxpayers from misapplying the statutory disposition rule in cases where the gain or loss from the disposition of the relevant foreign asset is recognized for U.S. income tax purposes but not for foreign income tax purposes.
Definitions of R&E Expenditures Are Amended Under Final Rules
The IRS issued final regulations on which amounts paid or incurred in connection with the development of tangible property, including pilot models, qualify for the Sec. 174 deduction (or amortization) for research and experimental expenditures.
Court Halts IRS Regulation of Contingent Fees for Refund Claims
A federal court granted summary judgment and issued an injunction to prevent the IRS from regulating contingent fee arrangements for the preparation and filing of ordinary refund claims under Circular 230.
Effective Date of Fiduciary Fee Unbundling Rules Delayed Until 2015
The new rules governing which costs of trusts and estates are subject to the 2% floor on miscellaneous deductions now apply to tax years beginning after Dec. 31, 2014, rather than to tax years beginning on or after May 9, 2014.
Partnership Interest Expense Allocation Rules Are Finalized
Final regulations make permanent four changes to the rules for allocating and apportioning interest expense for partners in partnerships.
AICPA Sues IRS to Stop Return Preparer Program
The AICPA filed suit in the U.S. District Court for the District of Columbia, asking the court to halt the IRS’s recently introduced Annual Filing Season Program.
Fighting Identity Theft, IRS Issues Final Rules on Truncated Identification Numbers
Final regulations allow the use of truncated taxpayer identification numbers on payee statements and certain other documents where not prohibited by the Code, applicable regulations, or other guidance published in the Internal Revenue Bulletin, forms, or instructions.
One-IRA-Rollover-a-Year Rule Will Be Effective in 2015, IRS Says
The IRS withdrew proposed regulations that provided that the one-rollover-per-year rule for IRAs applies on an IRA-by-IRA basis.
E-filing of Amended Returns, Elimination of Form 1040X Among TIGTA Recommendations
Taxpayers should be allowed to use Form 1040 to amend their returns and should be able to e-file amended returns, according to recommendations made by the Treasury Inspector General for Tax Administration.
Limit on Direct Deposit of Refunds Will Go Into Effect in 2015
Beginning in January 2015, the IRS will impose a limit of three electronic direct deposits of tax refunds into a single financial account or prepaid debit card.
Streamlined Tax-Exempt Application Process Introduced
The IRS introduced a streamlined application process for small organizations that want tax-exempt status under Sec. 501(c)(3).
Unused ITINs Will Expire After Five Years Under New IRS Policy
The IRS announced a new: ITINs that are not being used will expire after five years. The policy will go into effect in 2016.
IRA, Qualified Plan Participants Can Purchase Longevity Annuities
Final regulations issued permit IRA and qualified plan participants to enter into longevity annuities, using a certain amount of their account balances, without having these amounts count for calculating required minimum distributions.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
