Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline. Culp v. Commissioner is the first case in...more
A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
In its recent June Employee Plans newsletter, the Internal Revenue Service (IRS) announced the launch of a 90-day pre-examination compliance pilot program. Under the program, the IRS will notify a plan sponsor that its...more
Retirement plan sponsors should be aware of a new Internal Revenue Service (IRS) pilot program, which permits plan sponsors to conduct a pre-examination “check-up” of retirement plan administration before the IRS begins a...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022... March 29, 2022: The IRS issued a news release reminding...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 10, 2021 – May 14, 2021... May 10, 2021: The IRS issued Revenue Procedure 2021-25,...more
Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...more
Before the enactment of the 2017 Tax Cuts and Jobs Act (TCJA), qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property had a 15-year recovery period for depreciation...more
On April 9. 2020, the Internal Revenue Service (the “IRS”) issued Notice 2020-23, which extends a number of key filing deadlines in the wake of the COVID-19 pandemic. The guidance provides welcome relief to individuals and...more
IRS Grants Automatic Extension of Federal Tax Returns - Between March 17 and April 9, 2020, the U.S. Department of the Treasury and the Internal Revenue Service issued a series of notices automatically extending to July 15...more
As reported in our recent Client Alert, the IRS continued its series of tax relief announcements related to the COVID-19 emergency when it issued Notice 2020-23. This alert provides more detailed guidance on IRS Notice...more
NOTICE 2020-23 - On April 9, 2020, the U.S. Secretary of the Treasury issued Notice 2020-23. It greatly expands the tax compliance relief previously granted to taxpayers in response to the COVID-19 pandemic....more
In May 2019, the IRS issued Revenue Procedure 2019-20, which provides for a limited expansion of the determination letter program for certain individually-designed plans. Under this expansion, the IRS will accept...more
Beginning September 1, 2019, employers that sponsor cash balance plans and certain merged plans can sleep easier. Revenue Procedure 2019-20, issued by the Internal Revenue Service (IRS) on May 1, 2019, opens the IRS’s...more
On April 19, 2019, the Internal Revenue Service (“IRS”) released Revenue Procedure 2019-19 (the “Revenue Procedure”) and a separate IRS Release (the “Release”) updating the Employee Plans Compliance Resolution System...more
Since the end of the IRS’s cyclical determination letter program for individually designed retirement plans in 2017, plan sponsors have been able to request favorable determination letters for individually designed plans only...more
In guidance issued on April 19, 2019, the IRS expands the situations in which retirement plan sponsors can self-correct compliance failures without first having to seek IRS approval or paying a fee. Employers should be aware...more
On April 19, 2019, the Internal Revenue Service (IRS) released Revenue Procedure 2019-19, which updates its Employee Plans Compliance Resolution System (EPCRS). The new EPCRS significantly expands the use of retroactive plan...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8 – 12, 2019. April 8, 2019: The IRS issued a news release warning taxpayers against...more
Starting April Fools’ Day, all Voluntary Correction Program (VCP) submissions and fee payments under the IRS’s Employee Plans Compliance Resolution System (EPCRS) must be made online; the IRS will no longer process paper VCP...more
On September 28, 2018, the IRS released Revenue Procedure 2018-52. The Revenue Procedure makes changes to the IRS Employee Plans Compliance Resolution System (“EPCRS”), which is the IRS’ comprehensive correction program for...more
Through Revenue Procedure 2018-52, the Internal Revenue Service (IRS) has recently updated its system of correction programs for retirement plans known as the Employee Plans Compliance Resolution System (EPCRS). EPCRS permits...more
On March 5, 2018, the IRS released Revenue Procedure 2018-18, which, among other things, adjusts downward the 2018 total contribution limit to health savings accounts (HSAs) for individuals enrolled in family coverage. In...more