Get Ready for Enhanced IRS Enforcement

The Inflation Reduction Act significantly increased funding for the IRS, much of which goes to IRS enforcement efforts. In particular, the IRA appropriated $45.6 billion for enforcement, available until September 30, 2031. 

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Related Content 

• Yellen Says IRS To Staff Tax Centers with Funding Boost
  Learn about IRS staffing plans—with the IRS set to receive $80 billion in total additional funding under the Inflation Reduction Act, the agency will use part of the money to fully staff every tax assistance center by next year, as indicated by U.S. Treasury Secretary Janet Yellen during a September appearance at an IRS facility in New Carrollton, Maryland. "For too long, IRS tax assistance centers have been massively understaffed and under-resourced,” Yellen said during her visit.  

Legal Developments

• New Climate Law Expands Ways To Monetize Energy Credits
  Clean energy projects' access to existing and new energy tax credits is expected to go beyond the traditional tax equity financing with new ways to monetize the refunds under a sweeping new law that aims to tackle climate change.

• Leaving the United States: U.S. Tax Planning for U.S. Citizens and Tax Residents Temporarily or Permanently Leaving the U.S (September 2022)
  For U.S. citizens and/or tax residents (including most green card holders), the rules for filing income, estate, and gift tax returns and paying tax are generally the same regardless of where the individual lives. 

• Multinationals Face Most of Inflation Act’s Biz Taxes, Prof. Says
  Multinational corporations would bear most of a 15% minimum tax and a 1% tax on net share repurchases in the Inflation Reduction Act recently signed into law.

Practical Guidance Updates 
Featuring the latest updates from your Practical Guidance account.      

• Tax Key Legal Developments Tracker (Federal)
  Stay informed on new developments: 
  • Employment. The IRS released an advance version of Notice 2022-44, providing the 2022-2023 special per diem rates for taxpayers to use in substantiating the amount of ordinary and necessary business expenses incurred while traveling away from home. See prepublication draft.
  • Practice, Procedure and Controversy. Treasury issues proposed regulations reflecting provisions of the Taxpayer First Act of 2019 (Pub. L. No. 116-25), which codified the IRS Independent Office of Appeals in its role as the independent administrative appeals function within the IRS. 87 Fed. Reg. 55,934 (Sept. 13, 2022).
  • Practice, Procedure and Controversy. IRS provides a list of jurisdictions with which the U.S. has in effect a relevant information exchange agreement such that the requirement of Treas. Reg. §§ 1.6049-4(b)(5) and 1.6049-8(a) may apply regarding certain deposit interest paid to residents of such jurisdictions. Proc. 2022-35.
• Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts. 
• Check out the new Practical Guidance Author Center! Learn about the 1500+ leading attorney authors contributing to our 22 practice areas, and find out how you can Become a Practical Guidance Author.
• Share fundamental guidance with your firm’s new associates to help them sharpen their research and writing skills, get the inside scoop on associate survival, and hit the ground running in the tax practice area. Review the resources in the First Year Associate Resource Kit: Tax.
• The Practical Guidance Journal Fall Edition features impacts of the Dobbs v. Jackson Health Organization decision on employers, healthcare, insurance, and privacy concerns, and tracks the status of state law changes
• Listen up! Access our growing collection of podcasts by navigating to the Practical Guidance Podcasts Resource Kit.

• New and Recently Updated Practical Guidance Content
  • Hard-to-Value Intangibles
  • International Tax Consequences of Cryptocurrency Developments
  • Inflation Reduction Act of 2022: Tax Provisions
  • Statute of Limitations for Tax Returns (No Substantial Omissions)
  • Unauthorized Disclosure of Taxpayer Information (IRC Sections 6103 and 7431)
  • IRC Section 367 and Cross-Border Transfers

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