IRS Establishes Program for Rulings on Significant Issues
The IRS issued Rev. Proc. 2026‑21 on May 7, 2026, creating a program that lets taxpayers request rulings on specific, significant legal issues tied to transactions under sections 332, 351, 355, 368, or 1036. The initiative reinstates the practice of issuing letter rulings on parts of integrated transactions, aiming to use IRS resources more efficiently and speed up response times after numerous practitioner complaints. It excludes comfort rulings except for the listed sections and applies to requests postmarked or received after May 5, 2026.
IRS Offers Extension Option for Taxpayers Facing ERC Claim Deadlines
The IRS announced a streamlined process allowing eligible taxpayers to extend the two‑year deadline for resolving employee retention credit (ERC) disallowances. By filing Form 907 before the deadline expires, taxpayers can gain additional time for administrative review or to file a...
IRS Provides Guidance on Business Interest Limitation Elections
The IRS issued Revenue Procedure 2026‑17, allowing taxpayers to withdraw Sec. 163(j)(7) elections for excepted trades or businesses and to make a late Sec. 168(k)(7) election to forego bonus depreciation. The guidance implements changes from H.R. 1, which made 100 percent bonus depreciation permanent...
IRS Seeks to Scrap Basis‑shifting TOI Reporting Regulations
The Internal Revenue Service has issued proposed regulations to withdraw the basis‑shifting transaction‑of‑interest (TOI) reporting rules that were finalized in January 2025. The withdrawal would be treated as effective retroactively to Jan. 14, 2025, allowing taxpayers and advisers to consider the rules...
IRS Dirty Dozen Adds New Capital Gains Scheme for 2026
The IRS’s 2026 Dirty Dozen list introduces a new entry targeting abusive undistributed long‑term capital gains claims filed on Form 2439. Scammers are inflating or fabricating these filings, often linking them to nonexistent or misrepresented investment funds and real‑estate trusts. The...
GAO Says Tax Pros Helped Shape IRS Response to ERC Issues
The Government Accountability Office reported that tax practitioners shaped the IRS's response to the Employee Retention Credit (ERC), prompting a two‑part voluntary disclosure program, an updated eligibility‑tool website, and new professional‑responsibility guidance. The IRS says it has closed nearly five...
Anticipated Applicability Date for Future Final RMD Regs. Announced
The IRS announced in Announcement 2026‑7 that final regulations amending RMD rules will not take effect until at least the 2026 calendar year, roughly six months after their Federal Register publication. The interim guidance requires taxpayers to rely on a good‑faith...
AICPA Urges Treasury, IRS to Simplify Sec. 951 Documentation Rules
The AICPA sent a letter to the Treasury and IRS urging simplification of the “determine and document” requirement in Notice 2025‑75 related to Section 951 dividend inclusions. The notice obliges U.S. shareholders of controlled foreign corporations to attach a statement to...
Businesses Urge Treasury to Destroy BOI Data and Finalize Exemption
More than 100 business associations have written to Treasury urging the destruction of beneficial ownership information (BOI) records for domestic companies that no longer must file under the Corporate Transparency Act (CTA). They also request a final rule exempting U.S....
SECURE 2.0 Amendment Deadline Extended for IRAs, Other Retirement Plans
The IRS issued Notice 2026‑9, pushing the deadline for amending IRAs, SEP and SIMPLE IRA plans to comply with the SECURE 2.0 Act to at least Dec. 31 2027. The extension follows the agency’s need to finalize model amendment language that will guide trustees, custodians...
IRS Releases FAQs on Qualified Overtime Pay Deduction Under H.R. 1
The IRS issued Fact Sheet 2026‑01, a FAQ document clarifying the qualified overtime compensation deduction created by H.R. 1. It specifies that only the portion of overtime pay mandated by the Fair Labor Standards Act—typically the half‑rate above regular pay—qualifies for the...
IRS Advisory Council Report Defends Workers, Criticizes Budget and Staff Cuts
The IRS Advisory Council released its 2025 annual report defending the agency’s workforce while decrying recent budget rescissions and staff cuts. The report notes that more than half of the $80 billion Inflation Reduction Act funding earmarked for the IRS has...
AICPA Tax Policy and Advocacy Successes: 2025 Highlights
The AICPA Tax Division reported over 40 advocacy victories in 2025, including eight legislative successes—seven AICPA‑backed bills enacted and the defeat of a provision that would have barred state passthrough entity tax regimes. Twelve Treasury and IRS guidance items incorporated...