The IRS has proposed amending existing regulations under Sec. 312 and Sec. 381 to clarify that in certain corporate reorganizations, the “acquiring corporation” succeeds to the full E&P account of the transferor corporation.
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IRS Finalizes Regulations on Sec. 642(c) Ordering Rules for Estates and Trusts
The IRS issued final regulations requiring that a provision in a trust, will, or local law that specifically indicates the source out of which amounts are to be paid, permanently set aside, or used for a charitable purpose must have an independent economic effect aside from income tax purposes if the allocation is to be respected for federal tax purposes.
IRS Creates Priority Phone Service for Correspondence Audits
The IRS on April 2 launched a new toll-free phone service for tax professionals to use when responding to correspondence examination telephone calls or letters.
Colorado’s “Amazon” Law Requiring Out-of-State Retailers to Report Sales Held to Be Unconstitutional
A federal district court held that the Colorado law requiring out-of state retailers to report information about customers’ purchases to each customer and to the state is unconstitutional.
TIGTA Recommends Improvements to IRS Cybersecurity System
TIGTA reports that the IRS’s computer security response center is performing effectively, but further improvement is needed.
Medical Center’s FICA Refund Claim Dismissed as Untimely
The First Circuit dismissed a suit for refund of FICA taxes, upholding a lower court determination that discovery requests were not warranted and that the information sought from the IRS would not have proved that the refund claim, which the IRS claimed it never received, was timely.
Some Tax-Exempt Organizations Are Receiving Erroneous Penalty Notices; Relief Available
Practitioners are reporting that some tax-exempt organizations have received penalty notices from the IRS for late filing of Forms 990, even though they received an automatic extension and filed during March, as instructed by the IRS.
IRS and OECD Separately Address Transfer Pricing Issues
The IRS announced a reorganization of its advance pricing agreement (APA), mutual agreement, and competent authority programs into one new program.
TIGTA Calls for Improvements to IRS Volunteer Tax Prep. Program Database
TIGTA reported on its study of the IRS’s monitoring of volunteer tax preparation services.
Roth IRAs Cannot Be S Corporation Shareholders, Ninth Circuit Holds
The Ninth Circuit, affirming the Tax Court, held that a corporation whose sole shareholder was a Roth IRA was not a valid S corporation.
IRS Suspends Repair/Capitalization Exams Pending Accounting Method Changes
The IRS issued a directive for field examinations on the repair vs. capitalization issue that essentially suspended current examinations so as to permit taxpayers to file accounting method changes under just-issued revenue procedures.
New Online Search Tool Makes It Easier to Find Information About Exempt Organizations
The IRS announced that taxpayers can find information about tax-exempt organizations in a new online search tool called Exempt Organizations Select Check.
Prop. Regs. Would Require Taxpayers That Received EINs to Update Information
The IRS issued proposed regulations that would require taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS.
Tax Court Disallows Cost Segregation of Apartment Building Components
In a case exploring the extent of allowable cost segregation in depreciable rental real estate, the Tax Court held that all but a small handful of items identified by the building’s owner had to be depreciated over the life of the building.
IRS Issues Foreign-Targeted Bond Guidance
The IRS issued interim guidance on registration of foreign-targeted bonds and provided transitional relief for withholding agents on the related portfolio interest exception.
Much-Anticipated Guidance Issued on Accounting Method Changes for Repair Regs.
The IRS issued two revenue procedures detailing how taxpayers may obtain IRS automatic consent to the accounting method changes required by the rules.
IRS Expands “Fresh Start” Initiative, Provides Penalty Relief for Unemployed
The IRS announced an expanded “Fresh Start” initiative to help struggling taxpayers with a number of measures for relief.
Tax Court Says Limitation on Deductible Mortgage Interest Applies to Unmarried Co-Owners
The Tax Court held that unmarried co-owners were together subject to the $1.1 million limit on personal residence indebtedness under Sec. 163(h)(3).
2012 Automobile Depreciation Limits Released
The IRS issued the 2012 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
IRS Regulations Broaden Disclosures of Tax-Exemption Determinations
The IRS issued final regulations regarding disclosure of denials and revocations of tax-exempt status.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
