The regulations are procedurally invalid; the donor’s deed satisfied the statutory requirements, the court holds.
Tax
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?
Supreme Court: Insurance proceeds increase corporation’s estate tax value
In a unanimous decision, the Supreme Court holds that life insurance proceeds a corporation receives to fund a share redemption agreement increases the corporation’s estate tax value.
Expert warns: IRS has what it needs to pursue more audits
A speaker at AICPA & CIMA ENGAGE tells attendees that the IRS is paying higher salaries to attract midcareer workers as the agency increases audits.
Line items
Supreme Court to decide estate tax impact of life insurance in closely held businesses … Enforcement, voluntary programs yield over $1 billion from ERC claims … Werfel says digital initiatives can transform ‘iconically unpopular’ IRS … Federal court holds Corporate Transparency Act unconstitutional … Decision holding Corporate Transparency Act unconstitutional appealed
Criminally forfeited IRA distribution was constructively received and taxable
The Tax Court denies an incarcerated taxpayer’s arguments to the contrary.
IRS data reveals insights into collections, compliance, and criminals
A comprehensive exploration of the latest IRS data provides insights into compliance, revenue collection, and criminal activities.
Bias possible in IRS program for auditing refundable credit returns
The IRS said it agrees with the six recommendations from the Government Accountability Office to eliminate the bias.
Features
SPONSORED REPORT
Agentic accounting has arrived: What’s hype and what’s real?
Artificial intelligence (AI) is moving beyond chatbots and into accounting workflows. A new generation of agentic AI tools can plan, execute, and adapt as they complete tasks, raising expectations for what automation can do inside firms and finance departments. What can agentic AI realistically do today and what challenges are there in its implementation? Find out in this Journal of Accountancy sponsored report.
