On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more
On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more
6/1/2021
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FATCA ,
Financial Institutions ,
Internal Revenue Code (IRC) ,
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Proposed Legislation ,
Reporting Requirements ,
Tax Avoidance ,
Tax Penalties
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
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Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
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GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more
5/26/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
5/18/2021
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Biden Administration ,
Business Losses ,
Cryptocurrency ,
Financial Reporting ,
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Legislative Agendas ,
Priority Guidance Plan ,
Section 162(f) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
U.S. Treasury
The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received Paycheck Protection Program (PPP) loans in 2020 but did not deduct all of their...more
5/3/2021
/ Business Expenses ,
Business Taxes ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Revenue Procedures ,
Revenue Rulings ,
Safe Harbors ,
Tax Deductions
On Thursday, April 8, the IRS served up Notice 2021-25 (the Notice) providing guidance for taxpayers seeking to take advantage of the temporary 100-percent deduction for the cost of business meals, which was enacted by...more
On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of forgiven loans under the Paycheck Protection Program (PPP) are disallowed. On...more
On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more
Just in time to add to your holiday reading list, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations under sections 451(b) and 451(c) of the Code addressing income...more
On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more
Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...more
On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more
On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more
On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more
On Friday, April 10, 2020, the IRS released Rev. Proc. 2020-22 providing procedural guidance to taxpayers wishing to implement changes made by the CARES Act to the section 163(j) business interest deduction limitation. Under...more
On March 6, 2020, the Internal Revenue Service (IRS) released PLR 202010002, which provided the appropriate normalization treatment of infrastructure surcharges in supplemental rate proceedings as well as the proper...more
On September 6, 2019, the Internal Revenue Service (Service) issued Rev. Proc. 2019-37, which grants advance consent to taxpayers seeking to change a method of accounting to comply with the new proposed regulations under...more
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more
In CCA 201928014 (July 12, 2019), the IRS Office of Chief Counsel provides its view of the interplay between the net operating loss (NOL) carryover rules set forth in Internal Revenue Code (Code) § 172(b)(2) and the...more
On July 11, 2019, the Internal Revenue Service (Service) and Department of Treasury (Treasury) issued final regulations to remove Treas. Reg. § 1.451-5, which allowed taxpayers to delay reporting income with respect to...more
On May 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced changes in, and a new name for, a key compliance program (IR-2019-95) to identify the biggest and most...more
On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more