The AICPA’s vice president–Tax Policy & Advocacy said President Donald Trump’s executive order to freeze hiring at the IRS should not affect seasonal employees, who likely are already hired and trained.
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IRS Practice & Procedure
Werfel to resign Monday as IRS commissioner
Danny Werfel, who had two years remaining on his term, said he made the decision after “significant introspection and consultation.” An AICPA statement praised Werfel for “moving the IRS in the right direction to improve taxpayer services and start instituting modern technologies.”
Final regs address taxes on gifts to taxpayers from ex-U.S. citizens, residents
The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago.
Final regs. address resolution of federal tax controversies by Appeals
The final regulations, which include 24 exceptions to consideration of federal tax controversies by the Independent Office of Appeals, generally follow the proposed regulations issued in October 2022.
IRS testing changes to alternative dispute resolution programs
New pilot programs involve fast-track settlements and post-appeals mediation.
Prop. regs. address expanded annual compensation deduction limitation
The regulations provide guidance on determining who is one of the “five highest compensated employees” under Sec. 162(m)(3)(C).
Prop. regs. issued for spinoff transactions and their reporting
The IRS said it used feedback from tax advisers to write the proposed regulations, which include new multiyear tax reporting requirements.
Regs. identify microcaptive transactions as reportable transactions
The final regulations, posted by the IRS on Tuesday in the Federal Register, identify certain microcaptive transactions as reportable listed transactions or transactions of interest.
IRS announces start date for tax filing season
IRS Commissioner Danny Werfel said he expects the 2025 filing season to build on the success of the two previous seasons if Congress maintains funding.
IRS issues proposed regs. on catch-up contributions
The proposed regulations apply to catch-up contributions under a 401(k) or similar workplace retirement plan that generally are allowed for workers who have attained age 50.
Basis-shifting transaction reporting addressed in final regs.
The final regulations, which the IRS issued Friday, make several changes to the proposed regulations, including a higher dollar threshold for a basis increase in transactions of interest.
AICPA tax policy and advocacy successes: 2024 highlights
It’s worth pausing to reflect on the AICPA’s successes in advocating for the profession with Congress and the IRS during 2024.
IRS requires sustained funding to continue to help taxpayers, report says
The national taxpayer advocate’s first report to the new Congress highlighted the need for money devoted to taxpayer services and technology.
Plaintiffs ask Supreme Court to reject DOJ’s BOI request
In response to the Justice Department’s application for a stay of a district court injunction related to beneficial ownership information reporting, the plaintiffs claim that staying the injunction would harm reporting companies more than it would help the government.
Alternative methods allowed for identification of digital assets
The IRS provided temporary relief that permits eligible taxpayers to use alternative methods to make adequate identification of digital asset units sold, disposed of, or transferred in 2025.
Taxpayer may not deduct penalties imposed for violating a law
An IRS technical advice memorandum examines a taxpayer’s fines and penalties paid to a state agency.
Basket contracts would be listed transactions under proposed regs.
The regulations target improper income deferral and capital gain treatment using certain options, notional principal contracts, and other derivatives.
Strategies for information return penalties and Form 945 assessments
Penalties for failure to file correct information returns and backup withholding can be waived, but timely and correct responses to IRS notices are essential.
No Collection Due Process hearing for FBAR penalties
A hearing is available only for taxes imposed by Title 26, the Internal Revenue Code, as opposed to the taxpayers’ foreign bank account reporting penalties under U.S. Code Title 31, the Tax Court held.
Appeals court reinstates injunction that halts BOI enforcement
Three days after a panel of judges granted a government motion to lift the injunction, another panel said it was reinstating a lower court’s ruling. An AICPA statement urged CPAs to be prepared to file BOI reports. A statement by the Financial Crimes Enforcement Network said that, in light of the court ruling, companies could continue to file BOI reports voluntarily and that they are “not subject to liability if they fail to do so while the order remains in force.”
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.
