Ideas & Insights

TEGE will continue to provide flexibility on IDR enforcement timelines and modified examination procedures due to COVID-19.

The IRS created a new Form 1099-NEC to report nonemployee compensation with a different due date than Form 1099-MISC.

Court of Federal Claims holds delegating the filing, depositing and paying of employment taxes is not reasonable cause excusing penalties.

IRS addresses QSubs and period of limitations in a new set of proposed rules to the centralized partnership audit regime.

IRS Commissioner rejects blanket COVID-19 penalty relief and instead urges taxpayers to use first time abatement and reasonable cause.

Second settlement initiative for certain taxpayers under audit who participated in abusive micro-captive insurance transactions.

IRS new release announces extended Jan. 15, 2021 filing date for certain taxpayers affected by the September California wildfires.

IRS announces Feb. 16, 2021 extended tax filing, payment and other postponement relief for victims of Hurricane Delta.

The IRS announced that December 31, 2020 will be the last date to submit tentative net operating loss carryback claims via fax.

Section 6662(i) 40% penalty is an enhancement of section 6662(b)(6). Failed approval of section 6662(b)(6) cannot be cured later.

Chief Counsel Notice discusses frequent questions regarding settlement requirements for syndicated conservation easements.

IRS increases enforcement efforts and warns taxpayers to review reportable micro-captive transactions prior to October 15 tax deadline.

IRS provides specific guidance through proposed IRM provisions to implement interim policy changes for supervisory approval of penalties.

IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Hurricane Sally.

IRS to focus on taxpayer compliance with the documentation requirement to allocate and deduct success-based fees.

IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Oregon wildfires.

New IRS guidance updates and clarifies the previous ASC 730 Directive for R&D credit claims of LB&I Taxpayers using U.S. GAAP rules.

Tax Court ruled rejected e-filing triggered three-year limitation statute despite omission of taxpayer’s personal identification number.

The IRS expanded its previous temporary authorization of e-signatures to an additional 7 forms in response to the COVID-19 pandemic.

IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Hurricane Laura.