ERC; abusive use of partnerships; tax forums; open field collection cases; and more
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Issue Number:? 2024-25Inside This Issue
1.? Next phase of Employee Retention Credit work begins; review shows vast majority pose risk of being incorrect The IRS this week announced plans to reject thousands of improper high-risk Employee Retention Credit claims while starting a new round of processing lower-risk claims to help qualified taxpayers. The IRS recognized between 10% and 20% of claims fall into what the agency has determined to be the highest-risk group, which show clear signs of being erroneous claims for the pandemic-era credit. Tens of thousands of these will be denied in the weeks ahead. This high-risk group includes filings with warning indications that clearly fall outside the guidelines established by Congress. 2.? IRS unveils new measures to stop abusive use of partnerships, seeks to close major loopholes worth billions The IRS has unveiled a new set of initiatives to stop abusive partnership transactions that allow affluent taxpayers to avoid paying what they owe. The IRS wants to put an end to partnerships basis shifting, which is a method used by individuals and businesses to transfer assets to evade paying taxes. As a component of continuous initiatives to draw attention to the issues pertaining to high incomes, the IRS announced the establishment of a new dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, including closing loopholes. The office will work closely with a new pass-through work group being established in the IRS Large Business and International division that will be officially established this fall. 3.? 2024 IRS Nationwide Tax Forum: Digital services support New for 2024, attendees at the IRS Nationwide Tax Forum can join IRS experts in the Digital Account Services room to learn how to claim their IRS online accounts and gain real-time access to online services. In addition, the IRS Return Preparer Office will offer account services, giving tax professionals an on-site way to resolve issues they?re having with their practitioner accounts. Staff will assist tax pros with issues that extend beyond general program questions, such as:
Attendees should look for the new Digital Account Services room and make their appointments on-site. The 2024 IRS Nationwide Tax Forum begins in Chicago, July 9-11, and continues in Orlando, July 30-Aug. 1, Baltimore, Aug. 13-15, Dallas, Aug. 20-22, and San Diego, Sept. 10-12. For more information and to register, visit IRS Nationwide Tax Forum. 4.? Tax pro reminder: Taxpayers with an open field collection case can utilize online payment options Tax pros, if you are representing clients with an open field collection case, remind them they can make electronic payments. Payments can be sent to the revenue officer assigned to their case or paid directly to the IRS by visiting irs.gov/payments. There are several advantages to making online payments:
5.? IRS issues revised draft Form 6765, Credit for Increasing Research Activities? The IRS made public the availability of draft form 6765, popularly referred to as the Research Credit. Numerous external stakeholders provided insightful feedback to the IRS, which helped the agency make several changes aimed at lightening taxpayer burden. 6.? Educational assistance programs: Treasury, IRS issue FAQs The Department of Treasury and the IRS published frequently asked questions (FAQs) in Fact Sheet 2024-22, about questions pertaining to educational assistance programs under section 127 of the Internal Revenue Code (Code) (a section 127 educational assistance program). Certain educational assistance benefits that are given under an educational assistance program may be excluded by taxpayers from their gross income. Payments for tuition fees, and costs associated with books and supplies are among the benefits of the program. They also cover principal and interest payments for qualifying loans that an employer makes between March 27, 2020, and Jan. 1, 2026.? 7.? Upcoming webinars for tax practitioners The IRS offers the upcoming live webinar to the tax practitioner community:
For more information or to register, visit Webinars for tax practitioners webpage. 8.? News from the Justice Department?s Tax Division Tax return preparer John Borgela of Florida has been sentenced to two years in prison for preparing and filing false tax returns for others. By repeatedly understating customers? tax liabilities, the complaint alleges the United States has been harmed by Borgela?s conduct, resulting in a significant loss in tax revenue of $970,000. In addition to his prison sentence, Borgela is ordered to serve two years of supervised release and to pay $970,970 in restitution to the United States. IRS Criminal Investigation investigated the case.. Tax return preparer and business owner Salvador Gonzalez of California pleaded guilty to aiding in the preparation of false tax returns. According to court documents and statements made in court, Gonzalez inflated his clients? tax refunds by preparing and submitting to the IRS false tax returns that claimed fraudulent tax deductions and fictitious business profits and losses. Gonzalez is scheduled to be sentenced on Oct. 7 and faces a maximum penalty of three years in prison for each of the three counts of aiding and assisting in the preparation of false tax returns. He also faces a period of supervised release, restitution and monetary penalties. IRS Criminal Investigation is investigating the case. The Department of Treasury and the IRS released final rules on the prevailing wage and apprenticeship (PWA) requirements related to increased credit or deduction amounts for specific clean energy incentives, implemented under the Inflation Reduction Act (IRA). ?The increased credit or deduction for taxpayers meeting prevailing wage and apprenticeship requirements creates opportunities for both workers and employers,? said IRS Commissioner Danny Werfel. ?The IRS is committed to ensuring that taxpayers claiming the clean energy credits comply with all the applicable prevailing wage and apprenticeship requirements. The additional resources the IRS has received are making a difference for our efforts to ramp up taxpayer service and enforcement, and we will continue to build on these improvements.? Notice 2024-53 sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2024 used under section 417(e)(3)(D), the 24-month average segment rates applicable for June 2024, and the 30-year Treasury rates, as reflected by the application of section 430(h)(2)(C)(iv). Notice 2024-54 announces that the Department of the Treasury and the IRS intend to issue two sets of proposed regulations that would provide special rules for certain transactions under sections 732, 734, 743, 755 and 1502 of the Internal Revenue Code. Notice 2024-55 provides guidance on the application of the exceptions to the 10 percent additional tax under section 72(t)(1) of the Internal Revenue Code (Code) for emergency personal expense distributions and domestic abuse victim distributions. Revenue Ruling 2024-13 provides various prescribed rates for federal income tax purposes including the applicable federal interest rates, the adjusted applicable federal interest rates, the adjusted federal long-term rate and the adjusted federal long-term tax-exempt rate. These rates are determined as prescribed by section 1274. Revenue Ruling 2024-14 advises taxpayers of the Service?s position challenging certain partnership related-party transactions under the codified economic substance doctrine in section 7701(o). ? ? ?? ?? ?? ?? ?? ?? ?? ?? ?? ??? ?? ?Thank you for subscribing to e-News for Tax Professionals an IRS e-mail service. If you have a specific concern about your client's tax situation, call the IRS Practitioner Priority Service 1-866-860-4259. This message was distributed automatically from the mailing list e-News for Tax Professionals. Please Do Not Reply To This Message To subscribe to or unsubscribe from another list, please go to the e-News Subscriptions page on the IRS Web site. |
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