While the IRS has discretion to provide relief, Sec. 7508A(d) provides a mandatory tax deadline postponement. In either case, the ‘lookback’ limitation period for refunds remains a concern.
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IRS Practice & Procedure
Amended returns and the Sec. 965(k) six-year period for assessment
A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.
New commissioner confident IRS can implement OBBBA’s tax provisions
Commissioner Billy Long explained his management philosophy at the 2025 Tax Summit of the National Association of Enrolled Agents, where he said IRS employees will be able to implement the OBBBA’s tax provisions.
IRS staff cuts could put burden on practitioners to explain OBBBA
A retired IRS communications executive told the AICPA’s Town Hall that employees will be challenged to explain tax changes in the massive law.
IRS advises of Tuesday deadline to maintain Business Tax Account access
The IRS warned that those who do not revalidate accounts by Tuesday will need to request access to the account again, either as a designated official or other user type.
Congress passes act allowing tax relief when a state declares disaster
A bill supported by the AICPA is “a major win for taxpayers and tax practitioners,” according to a statement by President and CEO Mark Koziel. The bill, which now heads to President Donald Trump for his signature, is intended to speed up the granting of tax deadline extensions after a disaster.
AICPA: Guidance needed on catch-up contributions under Roth mandate
In a letter to Treasury and the IRS, the AICPA requested guidance on language in proposed regulations issued in January.
It’s no joke: Being nice is among this attorney’s top ways to deal with the IRS
Being nice is one of tax controversy attorney Melissa Wiley’s ways of getting answers from the IRS, which also includes knowing the Internal Revenue Manual and using self-service tools.
AICPA recommends changes to mandate ending federal disbursements by paper check
An executive order issued in March requires the Treasury secretary to cease issuing paper checks for all federal disbursements and requires all payments made by the federal government to be electronically processed.
IRS withdraws proposed regs. governing built-in losses and gains
The IRS said Tuesday that it expects to issue a revised notice of proposed rulemaking after it studies the issues addressed in the 2019 proposed regulations.
Microcaptive insurance arrangements subject to new rules
To protect against certain risks, businesses can create “captive” insurance companies. The final regulations designate certain microcaptive arrangements as reportable listed transactions or transactions of interest.
Bankruptcy trustee cannot avoid transfer of funds to IRS
A government waiver of sovereign immunity under the Bankruptcy Code does not apply to a state-law claim setting aside tax payments, the Supreme Court held.
Forfeiture of IRA is not a taxable distribution
A taxpayer whose individual retirement account was paid to the government under a criminal court order did not have taxable income as a result, the Sixth Circuit held, reversing the Tax Court.
IRS staffing, budget cuts threaten 2026 filing season, taxpayer advocate says
After a successful 2025 tax filing season, the loss of over 25% of staff and a 37% drop in funding leave the status of the 2026 season in doubt, the national taxpayer advocate’s midyear report said.
Lessons from a CPA whose firm delivered a ‘textbook response’ to data breach
The owner of a CPA firm in Texas told attendees at an AICPA & CIMA ENGAGE 25 session on data security that the breach was one of the hardest things she had experienced in her career, yet she came out of it with clients still viewing her positively.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Supreme Court: Tax Court lacks jurisdiction after removal of levy
Reversing the Third Circuit, the Court holds that the Tax Court lacked jurisdiction over a collection due process appeal of a levy once the taxpayer’s underlying tax liability was satisfied and the IRS removed the levy.
IRS provides additional transition relief for certain digital asset brokers
The relief applies to brokers who must report certain digital asset sales and exchanges on Form 1099-DA and is in response to public comment that brokers need more time to comply.
Senate confirms Billy Long as IRS commissioner
The former Missouri congressman is the sixth head of the IRS since January. He was confirmed by a vote of 53-44.
Automatic accounting method changes list updated by IRS
On Monday, the IRS provided a list of changes in tax accounting methods to which the automatic change procedures in Rev. Proc. 2015-13 apply. The list includes 17 changes described as significant.
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.
