A survey by the AICPA shows that almost two-thirds of tax professionals say it takes over 90 days to get a substantive response from the IRS to correspondence.
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Tax
Analyzing Moore: The ruling that upheld the Sec. 965 transition tax
Tony Nitti, CPA, reviews the Supreme Court opinion in Moore and details the potential repercussions. Listen to the episode or read the Q&A.
Final regs. issued for 1% excise tax on corporate stock repurchases
The final regulations provide guidance regarding the reporting and payment of the excise tax on repurchases of corporate stock made after Dec. 31, 2022.
IRS issues final regs. on reporting requirements for digital assets
The final regulations require custodial brokers to report transactions on Form 1099-DA, which the IRS will release soon. A different set of final regulations with rules for decentralized, or noncustodial, brokers will be issued later.
Second Circuit lacks jurisdiction in small tax case
Sec. 7463(b) forecloses a review of the Tax Court’s dismissal, the appellate court holds.
Line items
Final regs. issued for clean energy credit transfers … Draft of Form 1099-DA for reporting digital asset transactions released … IRS has mixed results from ‘ghost employer’ enforcement efforts … IRS grants limited waiver for underpayment of estimated corporate AMT … Proposed regs. issued for 1% excise tax on corporate stock repurchases … Auto depreciation limitations increase
Tax Court reverses course on conservation easement extinguishment regs.
The regulations are procedurally invalid; the donor’s deed satisfied the statutory requirements, the court holds.
Supreme Court overrules 40-year-old Chevron doctrine
The Court held that the APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority and not to defer to an agency’s interpretation of the law simply because a statute is ambiguous.
Settlement offers to be sent on syndicated conservation easements
The IRS is making a time-limited settlement offer to certain taxpayers who participated in syndicated conservation easements. The terms will require “substantial concession” of income tax benefits and the imposition of some penalties.
‘Unconscionable’ delays in ID theft cases mar IRS tax season: report
In her midyear report to Congress, National Taxpayer Advocate Erin Collins writes that, as of April, the IRS was taking over 22 months to resolve cases in its identity theft victim assistance unit, which had about 500,000 unresolved cases.
Final regs. issued on conservation easement deduction disallowance
The IRS on Monday issued final regulations providing guidance on the new rule that disallows charitable contribution deductions for certain conservation easement contributions by partnerships and other passthrough entities.
Supreme Court decision on Chevron doctrine will affect tax pros
The Court will rule by the end of its term Friday on the fate of the Chevron doctrine, which requires courts to give deference to a reasonable interpretation of an ambiguous statute by a government agency, including the IRS.
Exceptions to penalty on early retirement plan distributions outlined
The IRS issued guidance for exceptions for emergency personal expense distributions and for domestic abuse victim distributions.
IRS: Review of 1 million ERC claims reveals most show signs of risk
The IRS says that at least 10% of employee retention credit claims will be denied in the coming weeks and that at least 60% of claims show an “unacceptable” level of risk. The IRS will leave in place its moratorium on processing a majority of recent claims.
Supreme Court issues narrow opinion upholding Sec. 965 transition tax
The Supreme Court upheld the mandatory repatriation tax as a valid exercise of Congress’s taxing authority. The Court did not reach the question of whether income must be realized to be taxable.
Regs. cover green energy incentive wage and apprenticeship requirements
Under new final regulations issued by the IRS, taxpayers can generally increase the base amount of certain credits or deductions by five times when they meet prevailing wage and apprenticeship requirements.
IRS moves to end ‘shell game’ of basis-shifting transactions
The Service said it will release new proposed regulations and a revenue ruling to challenge the use of basis-shifting transactions used by complex partnerships in moves that could add over $50 billion to government coffers over 10 years.
IRS gives another limited estimated corporate AMT underpayment waiver
The IRS issued a notice extending earlier relief for a corporation’s failure to pay the part of estimated income tax attributable to the revised corporate alternative minimum tax.
9 months into ERC claim processing moratorium, still a waiting game
New employee retention credit (ERC) claims continue to be filed, and the IRS still has a backlog of claims from before a processing moratorium was announced in September. National Taxpayer Advocate Erin Collins says “soon” is the answer to when the moratorium will end. Meanwhile, some business owners sit and wait.
National taxpayer advocate: TikTok a difficult adversary for IRS
Speaking at ENGAGE, Erin Collins asks: How does the IRS fight bad tax advice on TikTok when employees are not supposed to access it?
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SPONSORED REPORT
Preparing clients for new provisions next tax season
As the 2025 filing season approaches, H.R. 1 introduces significant tax reforms that CPAs must be prepared to navigate. These legislative changes represent some of the most comprehensive tax updates in recent years, affecting both individual and corporate taxpayers. This report provides in-depth analysis and guidance on H.R. 1.
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