Recent academic journal articles of potential interest to tax practitioners investigated companies’ tax-avoidance behavior, knowledge sharing between accounting firms’ audit and tax personnel, the TCJA’s effects on US corporations’ debt structure and effective tax rates, and how cryptoasset investors respond to tax-compliance scrutiny.
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IRS Practice & Procedure
5 new warning signs of a bad claim for pandemic-era ERC
The IRS said the five signs are the result of what IRS compliance teams found while analyzing and processing claims for the employee retention credit (ERC). The Service plans to briefly reopen its voluntary disclosure program.
Funding spurs IRS improvements, but challenges remain, commissioner says
Commissioner Danny Werfel said the IRS is “reversing situations that have long hampered the IRS and frustrated taxpayers.” Treasury and the IRS announced continued improvements in digital systems, attributing those to funding from the Inflation Reduction Act.
Final and proposed regs. issued on retirement plan RMDs
The final regulations reflect changes to the required minimum distribution rules made by the SECURE Act and SECURE 2.0 and generally follow proposed regulations issued in 2022.
IRS collects $1 billion from high-income people who owed back taxes
The IRS is collecting on tax liabilities that were not “even in dispute,” Commissioner Danny Werfel said, but the IRS did not previously have the resources to pursue payment.
Proposed regs. address interest recapture on excess COVID-19 credits
The proposed regulations apply to overpayments of interest on erroneous refunds of COVID-19 credits paid on or after July 2.
Tax pros: IRS improving, but getting the right answer takes too long
A survey by the AICPA shows that almost two-thirds of tax professionals say it takes over 90 days to get a substantive response from the IRS to correspondence.
Final regs. issued for 1% excise tax on corporate stock repurchases
The final regulations provide guidance regarding the reporting and payment of the excise tax on repurchases of corporate stock made after Dec. 31, 2022.
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.
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.
