To make a valid election into the Bipartisan Budget Act’s audit procedures, the IRS could not require the taxpayer to establish, as opposed to represent, that it had sufficient assets to pay any imputed underpayment, the Tax Court held.
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IRS Practice & Procedure
IRS makes progress on backlogged ERC claims
The Service announced that it had digitized and categorized more than 1 million employee retention credit claims and would deny tens of thousands of those claims that it categorized as high-risk.
BOI reporting deadlines extended for certain victims of 5 hurricanes
The AICPA had requested that the Financial Crimes Enforcement Network extend reporting deadlines for beneficial ownership information for victims of hurricanes Beryl, Debby, Francine, Helene, and Milton.
IRS to end automatic penalties for late filing of foreign gift, bequest forms
National Taxpayer Advocate Erin Collins discussed the changes in a recent blog post. The changes have been long advocated by the AICPA.
Universal accounting for digital assets concludes, but safe harbor available
The new safe-harbor guidance for digital asset transaction reporting in Rev. Proc. 2024-28 goes into effect Jan. 1, 2025. This article explains how taxpayers may rely on the safe harbor to allocate unused basis of digital assets to digital assets held within each wallet or account of the taxpayer.
Annual inflation adjustments announced for tax year 2025
The IRS on Tuesday provided its annual inflation adjustments for over 60 tax provisions in tax year 2025, including increases in the standard deduction for married couples and single individuals.
IRS processing 400K ERC claims with about $10 billion in eligibility
Commissioner Danny Werfel says the IRS has made “substantial progress” in separating eligible claims from ineligible ones.
Intangible property repatriation rules finalized
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.
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.
Opportunity zone penalties: What constitutes reasonable cause?
Penalty relief for reasonable cause is worth exploring for faults in meeting the investment standard and asset tests despite exercising ordinary business care and prudence.
IRS increases corporate aircraft exams
These examinations may focus on qualification for bonus depreciation, substantiation of business use, and employee income imputation and deduction disallowance for personal use of aircraft.
Erroneous refund of interest does not support innocent-spouse relief
Taxpayer not entitled to equitable innocent-spouse relief for erroneous refund of interest.
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.
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.
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.
Supreme Court overturns Chevron doctrine
The 40-year old decision requiring judicial deference to the IRS’s and other federal agencies’ reasonable interpretations of ambiguous statutes was overruled in Loper Bright Enterprises, Inc.
Abdo could provide relief for other missed deadlines
The Tax Court’s decision invalidating regulations under Sec. 7508A creates uncertainty regarding IRS deadlines affected by disaster declarations.
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.
