June 17 tax deadline; tax forums; capacity limitation carryover guidance; and more

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e-News for Tax Professionals May 24, 2024

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Issue Number:? 2024-21

Inside This Issue

* Storm victims in seven states have until June 17 to file and pay [ #First ]
* IRS Nationwide Tax Forum: The benefits of attending [ #Second ]
* Treasury, IRS issue new rules on capacity limitation carryover amounts for 2024 program year [ #Third ]
* Treasury, IRS and DOE announce new allocation round for the qualifying advanced energy project credit [ #Fourth ]
* Upcoming webinars for tax practitioners [ #Fifth ]
* News from the Justice Department?s Tax Division [ #Sixth ]
* Technical Guidance [ #Seventh ]
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*1.? Storm victims in seven states have until June 17 to file and pay*

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Individuals and businesses in parts of seven states [ [link removed] ] that were affected by storms have until June 17 to file various federal individual and business tax returns and make tax payments. For areas designated by the Federal Emergency Management Agency [ [link removed] ] (FEMA), the IRS offers relief, including delaying various tax filing and payment deadlines. The June 17 deadline applies to taxpayers impacted by seven different disaster declarations. These include:


* One county in California [ [link removed] ];
* One county and two tribal nations in Connecticut [ [link removed] ];
* Nine counties in Michigan [ [link removed] ];
* Seven counties in Maine [ [link removed] ];
* Nine counties in Tennessee [ [link removed] ];
* Two counties in Washington [ [link removed] ]; and
* Six counties in West Virginia [ [link removed] ].? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ?

The current list of eligible localities is always available on the Tax relief in disaster situations [ [link removed] ] page on IRS.gov.
? ? ? ?

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*2.? IRS Nationwide Tax Forum: The benefits of attending*

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What do you get when you attend the IRS Nationwide Tax Forum? The tax forum registration fee includes all conference activities including seminars, exhibits and special events as well as the welcome reception on Tuesday and the networking reception on Wednesday. Registered attendees have full access to:


* More than 40 continuing education (CE) courses. Attendees can earn up to 19 credits. The conference agenda will be available by early June.
* The Exhibit Hall [ [link removed] ] for information on tax products and services that can help you and your business. Visit the IRS Zone to learn more about the IRS's vision for transformation and digitization and share your perspective with IRS representatives.
* The Case Resolution Program [ [link removed] ] for personalized assistance with your toughest tax case. IRS experts will be on-site for a one-on-one conversation, to conduct research on your case and endeavor to resolve your tax matter on site.
* Focus groups on a broad array of topics. Come share your opinion.
* Special bonus sessions on practice management, scams and schemes, and the new Treasury Department Beneficial Ownership Information reporting requirements.

Register now [ [link removed] ] and take advantage of the Early Bird rate (available until 5 p.m. June 17). Attendees who register early will have their badges mailed to them prior to the forum.

For more information about this year?s Nationwide Tax Forum, view the video, Five things to Know about the IRS Nationwide Tax Forum [ [link removed] ].

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*3.? Treasury, IRS issue new rules on capacity limitation carryover amounts for 2024 program year*

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The Treasury Department and the IRS announced proposed regulations that offer taxpayers new guidance [ [link removed] ] concerning the total amount of unallocated environmental justice solar and wind capacity limitation that has been carried over from the 2023 Low-Income Communities Bonus Credit program year to the 2024 program year. Announcement 2024-25 [ [link removed] ] states the distribution of the carried over capacity limitation among the facility categories, category 1 sub-reservations, and application options for the 2024 program year.

Visit the DOE program homepage [ [link removed] ] for additional guidance, final regulations and program resources to help applicants prepare their submissions.

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*4.? Treasury, IRS and DOE announce new allocation round for the qualifying advanced energy project credit*

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The Treasury Department, IRS and Department of Energy (DOE) announced a new round of allocations [ [link removed] ] for the qualifying advanced energy project credit. The DOE Qualified Advanced Energy Project Credit Program Applicant Portal [ [link removed] ] (48C Portal) is now open for applicants interested in registering for a new round of allocations. Applicants must submit their concept papers by June 21.

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*5.? Upcoming webinars for tax practitioners*

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The IRS offers the upcoming live webinar to the tax practitioner community:


* *Tax Considerations for H-2A Visa Holders (Agricultural Workers) and Employers* on June 6, at 2 p.m. ET. Earn up to 1 CE credit (Federal Tax). Certificates of completion are being offered.

For more information or to register, visit the Webinars for tax practitioners webpage [ [link removed] ].

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*6.? News from the Justice Department?s Tax Division*

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The U.S. District Court for the District of Connecticut issued a civil injunction suit to permanently bar Juan Carlos Frias [ [link removed] ] and his tax return preparation businesses from preparing federal tax returns for others. In the Justice Department?s complaint, Frias and his companies prepared more than 10,000 tax returns for customers, exhibit a pattern of filing tax returns that understated customers? liabilities and inflated their refunds by falsifying business expenses. Frias and his businesses consented to entry of the injunction, which permits the United States is allowed to conduct post-judgment discovery to monitor compliance with the order.

Kent Ellsworth [ [link removed] ] of Arizona pleaded guilty to assisting in the preparation of false income tax returns. In total, Ellsworth prepared more than 500 false tax returns and caused a tax loss to the IRS of approximately $17 million. He will be sentenced on Aug. 14 and faces a maximum penalty of three years in prison for each count of preparing and filing false tax returns. Ellsworth also faces a maximum fine of $250,000, a period of supervised release and the costs of prosecution for each count. IRS-Criminal Investigation is investigating the case.

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*7.? Technical Guidance*

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Announcement 2024-25 [ [link removed] ] provides the total amount of unallocated environmental justice solar and wind capacity limitation (Capacity Limitation) that has been carried over from the 2023 Low-Income Communities Bonus Credit Program (Program) year to the 2024 Program year.

Notice 2024-43 [ [link removed] ] amends regulations under sections 59A and 6038A to defer the applicability date of certain provisions of the regulations relating to the reporting of qualified derivative payments (?QDPs?).

Notice 2024-44 [ [link removed] ] provides guidance for complying with the final regulations with respect to dividend equivalents under IRC sections 871(m), 1441, 1461 and 1473 (collectively referred to as the section 871(m) regulations) in 2025, 2026 and 2027, extending the transition relief provided in Notice 2022-37, 2022-37 I.R.B. 234, for two years.

Rev. Proc. 2024-22 [ [link removed] ] obsoletes Rev. Proc. 82-2, 1982-1 C.B. 367, which identified the circumstances in which an organization could satisfy ? 1.501(c)(3)-1(b)(4) (requiring that the assets of a section 501(c)(3) organization be dedicated to an exempt purpose) by operation of the law of certain States or the District of Columbia.

Rev. Rul. 2024-10 [ [link removed] ] obsoletes Rev. Rul. 75-38, 1975-1 C.B. 161, which identified the District of Columbia and each State with statutory provisions that, in 1975, satisfied the private foundation governing instrument requirements of section 508(e).?

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