The final regulations provide guidance regarding the reporting and payment of the excise tax on repurchases of corporate stock made after Dec. 31, 2022.
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IRS Practice & Procedure
IRS issues final regs. on reporting requirements for digital assets
The final regulations require custodial brokers to report transactions on Form 1099-DA, which the IRS will release soon. A different set of final regulations with rules for decentralized, or noncustodial, brokers will be issued later.
IRS penalties, abatements, and other relief
Taxpayers and their advisers can benefit from a thorough understanding of law and procedures concerning abatement and other relief from tax penalties.
Deficiency notice invalid because IRS cannot prove last known address
The Tax Court held the Service did not show it followed its regulations and procedures to update a taxpayer’s address to which it sent the notice.
D.C. Circuit holds IRS can assess Sec. 6038(b) penalties
Reversing the Tax Court, the appellate court held the statute gives the IRS authority to assess the penalties for failing to file information returns disclosing ownership in foreign corporations.
Supreme Court overrules 40-year-old Chevron doctrine
The Court held that the APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority and not to defer to an agency’s interpretation of the law simply because a statute is ambiguous.
Settlement offers to be sent on syndicated conservation easements
The IRS is making a time-limited settlement offer to certain taxpayers who participated in syndicated conservation easements. The terms will require “substantial concession” of income tax benefits and the imposition of some penalties.
‘Unconscionable’ delays in ID theft cases mar IRS tax season: report
In her midyear report to Congress, National Taxpayer Advocate Erin Collins writes that, as of April, the IRS was taking over 22 months to resolve cases in its identity theft victim assistance unit, which had about 500,000 unresolved cases.
Final regs. issued on conservation easement deduction disallowance
The IRS on Monday issued final regulations providing guidance on the new rule that disallows charitable contribution deductions for certain conservation easement contributions by partnerships and other passthrough entities.
Supreme Court decision on Chevron doctrine will affect tax pros
The Court will rule by the end of its term Friday on the fate of the Chevron doctrine, which requires courts to give deference to a reasonable interpretation of an ambiguous statute by a government agency, including the IRS.
IRS: Review of 1 million ERC claims reveals most show signs of risk
The IRS says that at least 10% of employee retention credit claims will be denied in the coming weeks and that at least 60% of claims show an “unacceptable” level of risk. The IRS will leave in place its moratorium on processing a majority of recent claims.
Regs. cover green energy incentive wage and apprenticeship requirements
Under new final regulations issued by the IRS, taxpayers can generally increase the base amount of certain credits or deductions by five times when they meet prevailing wage and apprenticeship requirements.
9 months into ERC claim processing moratorium, still a waiting game
New employee retention credit (ERC) claims continue to be filed, and the IRS still has a backlog of claims from before a processing moratorium was announced in September. National Taxpayer Advocate Erin Collins says “soon” is the answer to when the moratorium will end. Meanwhile, some business owners sit and wait.
National taxpayer advocate: TikTok a difficult adversary for IRS
Speaking at ENGAGE, Erin Collins asks: How does the IRS fight bad tax advice on TikTok when employees are not supposed to access it?
Expert warns: IRS has what it needs to pursue more audits
A speaker at AICPA & CIMA ENGAGE tells attendees that the IRS is paying higher salaries to attract midcareer workers as the agency increases audits.
Petition timely filed as regulations held invalid
Regulations governing the time for filing a Tax Court petition during a federally declared disaster are invalid, and the taxpayers met Sec. 7508A(d)’s mandatory postponement provision, the court holds.
Third Circuit rejects IRS’s mootness claims
The IRS’s setoffs of estimated payments against the taxpayer’s deficiencies were invalid, the court finds, making the taxpayer’s lawsuit a live case or controversy.
Bias possible in IRS program for auditing refundable credit returns
The IRS said it agrees with the six recommendations from the Government Accountability Office to eliminate the bias.
IRS free filing program to become permanent with expanded scope
Commissioner Danny Werfel said the successful pilot program of Direct File encouraged the IRS to make the program available in all states and the District of Columbia.
AICPA makes recommendations to IRS on next Priority Guidance Plan
In addition to the guidance on the plan, the letter recommends that Treasury and the IRS continue pursuing tax simplification.
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.
