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.
Tax
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.
Filing season quick guide — tax year 2024
Download and print our annual quick guide, a tax season reference, highlighting dollar thresholds, tax tables, standard amounts, credits, and deductions.
Whistleblower case is not stayed by taxpayer’s bankruptcy case
Pursuant to Section 362(a)(8) of the Bankruptcy Code, a taxpayer’s bankruptcy filing did not automatically stay the Tax Court from hearing his whistleblower case.
Appeals court reinstates injunction that halts BOI enforcement
Three days after a panel of judges granted a government motion to lift the injunction, another panel said it was reinstating a lower court’s ruling. An AICPA statement urged CPAs to be prepared to file BOI reports. A statement by the Financial Crimes Enforcement Network said that, in light of the court ruling, companies could continue to file BOI reports voluntarily and that they are “not subject to liability if they fail to do so while the order remains in force.”
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.