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TOPICS
IRS Practice & Procedure
Beware of IRS initiatives against microcaptive insurance arrangements
Microcaptive insurance arrangements have been vigorously scrutinized recently by the IRS.
Corporation not covered by economic hardship exception
The economic hardship exception to a levy does not apply to corporations.
Videoconferencing with IRS now an option for all LB&I taxpayers
The IRS announced it is expanding the availability of videoconference meetings for large business taxpayers for examinations and appeals.
IRS addresses taxpayer reliance on FAQs, will save copies of old FAQs
Taxpayers who reasonably rely on FAQs posted by the Internal Revenue Service will have a reasonable-cause penalty defense under a new policy announced by the agency on Friday. The IRS will also keep original versions of FAQs on its site after it updates them.
Extrinsic evidence not allowed to prove when amended return filed
Extrinsic evidence is not allowed to prove the mailing date of an amended return where the envelope it was delivered in did not have a postmark.
Penalty for failure to report distribution from foreign trust not reduced
The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the trust owner.
IRS continues focus on cryptoassets
In response to tax evasion concerns with the use of virtual currencies, in 2021 the IRS established a new program titled ‘Operation Hidden Treasure.’
Taxpayer First Act changes innocent spouse relief
Changes significantly affect how an innocent spouse
case is prepared and places an increased burden on return preparers who interact with a taxpayer who potentially has an innocent spouse claim.
IRS launches ‘Tax Pro Account’ feature
A new online portal automates the submission of powers of attorney and tax information authorizations, and there are plans to expand its functionality over time.
Final regulations establish a user fee for estate tax closing letters
The letters, which the IRS provides as a courtesy to executors and other authorized estate representatives, will now cost $67.
Transcript Delivery System down for some Form 941 transcripts
The IRS reports that its Transcript Delivery System is down for business taxpayers who reported information related to COVID-19 employment tax relief on Form 941, Employer’s Quarterly Federal Tax Return.
Practitioners’ role in the continuing evolution of Circular 230
Practitioners and the organizations they are involved with can participate in facilitating the ongoing applicability and effectiveness of Circular 230.
AICPA supports bill to regulate tax preparers
A bill proposed in Congress would authorize Treasury to regulate paid tax return preparers, and the AICPA strongly supports it.
Supersized ‘Dirty Dozen’ highlight top tax tricks and abuses
Hijacking of economic impact payments and unemployment checks are spotlighted in the IRS’s annual alert, which warns taxpayers of the most prevalent scams and schemes the Service has identified.
Regs. address ambiguities in disaster postponement of deadlines
New IRS final regulations clarify when a federally declared disaster will lead to mandatory 60-day postponement of certain tax-related deadlines.
Budget and Greenbook detail Biden’s tax proposals
The proposed $6 trillion fiscal year 2022 budget unveiled by the Biden Administration includes a host of tax items, including proposals to raise the corporate tax rate, raise the top tax rate for high-income individuals, limit like-kind exchanges, and make permanent recent temporary changes to various tax credits.
Suit challenging information reporting requirements can go forward
The Supreme Court held that the Anti-Injunction Act did not bar a challenge to information reporting
requirements backed by separate tax penalties.
AICPA outlines key points for paid preparer regulation legislation
The Biden administration says the IRS should be given the authority to regulate paid tax return preparers who are currently unregulated, and the AICPA offers its recommendations in six key areas.
AICPA recommends further IRS pandemic relief measures
An AICPA letter to the IRS recommended several penalty relief measures to mitigate the pandemic’s effects and minimize required contacts with the IRS.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
