The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation.
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TOPICS
Tax
TIGTA says IRS should review $42 billion in ERC claims
The Treasury Inspector General for Tax Administration estimated that a change in policy for pre-refund examinations resulted in payment of $2 billion in erroneous employee retention credit claims.
Final regs. target syndicated conservation easement transactions
The IRS issued the final regulations identifying these abusive transactions and substantially similar ones as listed transactions that must be reported to the agency.
IRS provides Helene relief; AICPA seeks BOI, FBAR filing extensions
The IRS said it was providing disaster relief for individuals and businesses in all or part of seven states. Also, the AICPA sent a letter to FinCEN seeking extensions for BOI and FBAR reports that match the relief that the IRS provides for other filings, both in terms of the extended due dates and geographic scope.
Tax planning for the SALT cap
Taxpayers can employ several strategies in the face of limited deductibility of state and local taxes through 2025 and perhaps beyond.
Line items
Supreme Court overrules 40-year-old Chevron doctrine … IRS collects $1 billion from high-income people who owed back taxes … Proposed regs. address interest recapture on excess COVID-19 credits … Tax pros: IRS improving, but getting the right answer takes too long … Final regs. issued for 1% excise tax on corporate stock repurchases … IRS issues final regs. on reporting requirements for digital assets
Partnership made a valid election into the BBA procedures
The IRS could not require that the taxpayer prove, as opposed to represent, that it had enough assets to pay any imputed underpayment, based on the regulation’s plain text.
Lack of facts precludes equitable tolling of 30-day filing deadline
The Tax Court dismissed a taxpayer’s petition due to a missed filing deadline and lack of any facts that would entitle him to equitable tolling of the deadline.
ERC supplemental claim process opened for third-party payroll companies
The IRS announced that it will open a supplemental claim process to help third-party payers and their clients resolve incorrect claims for the employee retention credit. The deadline is Nov. 22.
IRS increases special per diem rate for business travel
The special per diem rates that a taxpayer uses in travel and business expenses will be higher starting Oct. 1, as provided by the IRS.
JofA highlights: Tackling accounting’s talent shortage, ChatGPT tips
The JofA’s editor-in-chief highlights the news, features, and advice that CPAs will find useful in recently published and upcoming issues of the magazine. Listen to the podcast episode or read the transcript.
Final regs. issued on consistent-basis and basis-reporting rules
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.
Proposed regs. would exclude tribal general welfare benefits from income
The first proposed regulations under Sec. 139E set out the requirements for excluding Indian tribal general welfare benefits from income.
Corporate AMT proposed regulations issued; some penalties waived
The IRS issued proposed regulations providing guidance on the corporate alternative minimum tax (AMT) and a notice that waives the penalty for failure to pay estimated tax with respect to the corporate AMT for 2024.
IRS seeks comments on SECURE 2.0 saver’s match contributions
Treasury and the IRS issued a notice on saver’s match contributions to be paid by Treasury under provisions of SECURE 2.0.
Cryptoasset ‘staking’ challenge dismissed as moot after government’s concession
Sixth Circuit affirms district court’s holding that the taxpayer’s refusal to cash a refund check did not keep the controversy alive in his case.
Line items
Supreme Court: Insurance proceeds increase corporation’s estate tax value … 9 months into ERC claim processing moratorium, still a waiting game … National taxpayer advocate: TikTok a difficult adversary for IRS … Expert warns: IRS has what it needs to pursue more audits … Bias possible in IRS program for auditing refundable credit returns … AICPA makes recommendations to IRS on next Priority Guidance Plan
Credit card reward liabilities may be eligible for recurring-item exception
The Office of Chief Counsel approves
accrual of liability, distinguishing the
situation in a CCA from that of Giant
Eagle, Inc.
Taxation of influencers: Gifts with strings attached?
Individuals promoting retail brands to their online audience may need to report taxable compensation for any benefit received.
Tax Court lacks jurisdiction because notice of deficiency was invalid
The court held that the notice was not sent
to the taxpayer’s last known address.
Features
FROM THIS MONTH'S ISSUE
Flip out with the latest Tech Q&A
The September Technology Q&A column shows how to create dynamic to-do lists with Excel's checkboxes and also how to set up multifactor authentication texts that don't rely on phones. Flip through both items and view a video walkthrough in our digital format.
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