The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation.
News
TIGTA says IRS should review $42 billion in ERC claims
The Treasury Inspector General for Tax Administration estimated that a change in policy for pre-refund examinations resulted in payment of $2 billion in erroneous employee retention credit claims.
Final regs. target syndicated conservation easement transactions
The IRS issued the final regulations identifying these abusive transactions and substantially similar ones as listed transactions that must be reported to the agency.
IRS provides Helene relief; AICPA seeks BOI, FBAR filing extensions
The IRS said it was providing disaster relief for individuals and businesses in all or part of seven states. Also, the AICPA sent a letter to FinCEN seeking extensions for BOI and FBAR reports that match the relief that the IRS provides for other filings, both in terms of the extended due dates and geographic scope.
ERC supplemental claim process opened for third-party payroll companies
The IRS announced that it will open a supplemental claim process to help third-party payers and their clients resolve incorrect claims for the employee retention credit. The deadline is Nov. 22.
IRS increases special per diem rate for business travel
The special per diem rates that a taxpayer uses in travel and business expenses will be higher starting Oct. 1, as provided by the IRS.
Final regs. issued on consistent-basis and basis-reporting rules
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.
Proposed regs. would exclude tribal general welfare benefits from income
The first proposed regulations under Sec. 139E set out the requirements for excluding Indian tribal general welfare benefits from income.
Corporate AMT proposed regulations issued; some penalties waived
The IRS issued proposed regulations providing guidance on the corporate alternative minimum tax (AMT) and a notice that waives the penalty for failure to pay estimated tax with respect to the corporate AMT for 2024.
IRS seeks comments on SECURE 2.0 saver’s match contributions
Treasury and the IRS issued a notice on saver’s match contributions to be paid by Treasury under provisions of SECURE 2.0.
Fact sheet addresses taxability of crowdfunding distributions
The IRS said that crowdfunding distributions may be included in the gross income of the person receiving them, depending on the facts and circumstances of the distributions.
Employers now have interim guidance on student loans and retirement plans
The IRS provided guidance for sponsors of 401(k) and similar retirement plans that provide matching contributions based on eligible student loan payments made by participating employees.
AICPA joins coalition to fight intensifying tax scams, schemes
The Coalition Against Scam and Scheme Threats (CASST), convened at the request of IRS Commissioner Danny Werfel, will work toward having new protections in place by the 2025 filing season.
Businesses with dubious ERC claims have another chance with the IRS
The IRS said Thursday it will reopen its voluntary disclosure program to allow businesses to correct questionable claims for the pandemic-era employee retention credit.
2024 tax software survey
CPAs assess how their return preparation products performed.
IRS releases updated draft of Form 1099-DA for digital assets
The most recent draft of the form for reporting digital asset transactions reflects the final regulations for custodial broker reporting that the IRS released in June.
FinCEN uses TV ad to tell businesses about BOI
The PSA uses a chat between friends in a coffee shop to educate small businesses about beneficial ownership information reporting, which 32.6 million businesses must file.
ERC disallowance letters go to 28K businesses, moratorium adjusted
The IRS moved the moratorium date forward into early 2024. Also, it announced sending disallowance letters to some businesses with invalid claims and plans for payments to others.
BOI requirements roll along despite concerns about too little outreach
FinCEN, which oversees beneficial ownership information reports, has received just 2.7 million of the 32.6 million reports that it expects. Through June, FinCEN said, it has reached more than 90,000 stakeholders.
Tax practitioner complaint leads to review of advocate phone service
A tax practitioner complained about a six-week wait for a response to help a client with a financial hardship who was owed a refund, leading to the unflattering review by the Treasury Inspector General for Tax Administration.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.