This week we look at:

• New work in progress to try and obtain a bipartisan tax bill
• IRS gives car dealers a brief extension to file time-of-sale reports
• IRS reverses direction on treatment of impact of adding a tax reimbursement clause to an IDGT
• Taxpayer can rely upon date IRS places in Notice of Deficiency as the last day to file a Tax Court petition

This week, we look at FinCEN's release of the BOI E-Filing site on January 1, 2024.

This week we look at:

• IRS announces a three month Employee Retention Credit Voluntary Disclosure Program
• IRS provides relief from failure-to-pay penalties for 2021 and 2020 taxes for certain situations
• Taxpayer uses the wrong FedEx service, therefore his Tax Court petition was not filed on time

This week we look at:

• FinCEN adds more information to FAQ page, including information on PDF form
• Bill passes House that would give a limited extension of time for some initial BOI reports to be filed
• IRS releases mileage rates for 2024
• Supreme Court agrees to hear estate tax valuation case to resolve split in the Circuits

This week we look at:

• IRS sends out a batch of 20,000 ERC rejection letters
• Employer files suit claiming IRS ERC guidance violated the Administrative Procedures Act
• SCOTUS hears oral arguments in the Moore case
• Draft K-2/K-3 instructions are published with no major changes to the domestic filing exception for 2023

This week we look at:

• FinCEN finalizes extension of due date for initial BOI reports for entities created in 2024
• Tax Court rules that a state law limited partner is not automatically covered by IRC §1402(a)(13) self-employment tax exemption
• OPR due diligence alert on FBAR
• Annual business MeF shutdown date announced
• IRS denies request for automatic accounting method change late election relief
• Tax Court finds that if date to file a Tax Court petition falls on a date that the clerk’s office is inaccessible, the taxpayer qualifies for extended filing relief even though electronic option had been available on the due date

This week we look at:

• IRS clarified FAQ on §139A and backpay for wrongfully incarcerated members of the armed services
• FinCEN adds to the FAQ on beneficial ownership information reporting

This week we look at:

• Inflation adjusted numbers for 2024 issued by the IRS
• Minor revisions made in final BOI FinCEN Identifier rules
• The IRS issues its second ERC-related GLAM, this time taking aim at OSHA related partial shutdown theories
• If a Notice isn’t binding on the courts, does that mean we can just pretend it doesn’t exist when advising our clients?

This week we look at:

• 2024 inflation adjusted retirement numbers released by the IRS
• MeF 1040 shutdown date announced by the IRS
• Trust found liable for transferee tax in failed Son-of-BOSS shelter to offset stock sale gain
• IRC §41 refund claim grace period extended for yet another year
• Tax Court refuses to expand equitable relief for missing 90-day deadline to file petition

This week we look at

• Taxpayers can’t rely on paid preparer as reasonable cause for late filing, even when using electronic filing
• IRS could assert negligence penalty (and obtain supervisory approval) after failing to obtain approval for substantial underpayment penalty
• IRS makes “temporary” electronic signature program permanent by moving it into the Internal Revenue Manual