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Tax
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.
Prop. regs. address 401(k), 403(b) automatic enrollment requirement
The proposed regulations provide guidance to plan administrators on implementing the automatic enrollment requirement established by the Secure 2.0 Act.
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.
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.
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.
Line items
IRS processing 400K ERC claims with about $10 billion in eligibility … Social Security wage base announced for 2025 … Intangible property repatriation rules finalized … TIGTA says IRS should review $42 billion in ERC claims … Final regs. target syndicated conservation easement transactions
Tax season 2025 preview
Practitioners should address regulatory changes, focus on practice management, and help clients plan for the scheduled TCJA sunset.
Equitable and collateral estoppel fail to shield S corporation distribution
Divorce, bankruptcy, and death ultimately result in taxable S corporation distribution for surviving shareholder.
When does a tax-exempt organization qualify for the ERC under the controlled-group rules?
A reasonable, good-faith interpretation of the rules must be applied, the IRS Chief Counsel’s Office states.
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