Buried in the regulations are optional or necessary actions to be taken in certain circumstances by holders of debt instruments, issuers of debt instruments subsequently registered with the SEC, and securities issuers that undertake organizational actions affecting the basis of specified securities.
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IRS Practice & Procedure
IRS Proposes Increased User Fees for Installment Agreements, Offers in Compromise
The IRS issued proposed regulations to raise user fees for installment agreements and for offers in compromise.
Amounts on Late-Filed S Corporation Return Were Not Disclosed on Taxpayer’s Return
For purposes of determining whether there had been a substantial understatement of gross income on a taxpayer’s return, the IRS determined that amounts on a Form 1120S filed after the three-year statute of limitation expired, were not considered to be disclosed on a taxpayer’s Form 1040.
Final Rules Issued on IRS Disclosure of Tax Return Information Under Health Care Law
The IRS issued final regulations about how it will release certain tax return information to the Department of Health and Human Services, as required by 2010’s health care legislation.
Disclosure Authorization and Electronic Account Resolution E-Services Get Three-Week Reprieve
The IRS announced that it is delaying the retirement of the Disclosure Authorization (DA) and Electronic Account Resolution (EAR) electronic services for three weeks.
Proposed Rules Reset Limitation for Pursuing Equitable Innocent Spouse Relief
The IRS issued proposed regulations under Secs. 6015(f) and 66(c) changing the deadline for taxpayers to request innocent spouse relief from joint liability.
Aug. 30 IRS Furlough Day Canceled
The IRS announced that it will remain open on Aug. 30, canceling a previously scheduled furlough day.
IRS Releases Draft Net Investment Income Tax Form
The IRS released a draft of Form 8960, a new dual-purpose form that will be used by individuals and trusts and estates to compute the new 3.8% net investment income tax.
White House Announces Nominee for IRS Commissioner
The White House announced that President Barack Obama will nominate John Koskinen as the new IRS commissioner.
Taxpayers Receive Notice That IRS Is Resolving Form 3520 Processing Issues
The IRS plans to send out letters to taxpayers who filed Form 3520 or Form 3520-A as it attempts to close out outstanding inquiries/correspondence involving Form 3520 prior processing issues.
Comments Requested on Proposed Net Investment Income Tax Form
The IRS published a notice and request for comments from taxpayers on a new dual-purpose form that will be used by individuals and trusts and estates to compute the new 3.8% tax and then to report the tax.
Identity Theft Protection Process at IRS Needs Improvements, TIGTA Says
TIGTA recently audited the IRS’s Taxpayer Protection Program to assess how the Service is handling the explosive growth in tax return identity theft in recent years.
July 22 IRS Furlough Day Canceled
The IRS has canceled its scheduled furlough day for Monday, July 22, acting IRS chief Danny Werfel announced.
IRS Provides Details About Postponed Employer Health Care Penalty and Information Reporting
The IRS made official the postponement of the large-employer health care penalty and certain information reporting rules that had been informally announced July 2.
Treasury Postpones Employer Health Care Penalty, Information Reporting for One Year
Large employers who fail to provide minimum health coverage for employees will not be subject to the shared-responsibility penalty until 2015 after Treasury announced that it would delay certain provisions of 2010’s health care legislation.
Questions on EINs in F Reorganizations Involving Disregarded Entities
Until the IRS issues clarifying guidance on whether a corporation that converts to an LLC always must retain its historic EIN, potential procedural conflicts may exist in relying on Rev. Rul. 73-526 to retain an EIN in an F reorganization.
Unresolved Issues Regarding Sec. 6603 Deposits
Can a taxpayer convert a Sec. 6603 deposit into an advance payment of tax? What happens if some or all of the remittance is later returned or refunded to the taxpayer?
The Collection Appeal Procedures and Collection Due Process Programs
How does a person recover from the economic crisis when the IRS is beating on the door with notices on a daily basis?
Final Regs. Require EIN Holders to Update Information With IRS
The IRS issued final regulations requiring taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS.
Advising Clients Regarding Erroneous Tax Return Positions: Part II
This article discusses what tax practitioners must do if their client fails to heed their advice whan an error is found on a tax return and what to do when the error is attributable to the tax practitioner’s own advice.
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.
