IRS Commissioner John Koskinen warned that the IRS may have to delay the start of the 2015 filing season, as well as the processing of refunds.

The IRS has concluded in field attorney advice that two corporations formed immediately prior to an asset sale were ignored for U.S. federal income tax purposes.

The IRS concluded in field attorney advice (FAA 20163701F) that a fee related to the termination of a merger agreement resulted in a capital loss to a taxpayer under Section 1234A.

The IRS has released field attorney advice denying bonus depreciation to the owner and operator of a hotel complex because the taxpayer failed to demonstrate when costs were incurred for each property.

The IRS determined what a taxpayer must do if it has deferred recognizing revenue into income under Rev. Proc. 2004-34 and its stock is subsequently acquired by an unrelated corporation...

The IRS addressed the appropriateness of applying the "self-comparable exception" and the "third party comparable exception" to determine if the gross receipts derived from the disposition of computer software qualified for purposes of Section 199.

The IRS has issued additional transition relief (Notice 2016-40) for employers who claim the work opportunity tax credit (WOTC) for employees hired between Jan. 1, 2015, and Aug. 31, 2016.

The IRS has finalized its 2003 proposed regulations on noncompensatory partnership options.

The IRS finalized its regulations on the medical device excise tax and released interim guidance that provides safe harbor rules for determining constructive sales price.

Legislation enacted last July imposed new reporting requirements on estates filing estate tax returns after July 31, 2015.

The IRS has released a private letter ruling extending the time for a corporation to elect safe harbor treatment under Rev. Proc. 2011-29 for a success-based transaction fee.

The IRS has finalized regulations (T.D. 9588) that explain how to allocate prepaid qualified mortgage insurance (QMI) premiums.

The final regulations provide for the treatment of an integrated transaction when the taxpayer disposes of or otherwise terminates all or a portion of the QDI or the hedge before maturity.

The IRS on July 2 issued final regulations relating to the purchase of qualified longevity annuity contracts under qualified defined contribution retirement plans.

Treasury and the IRS intend to issue regulations addressing the application of Section 901(m) to disposition of assets following covered asset acquisitions.

The IRS issued Notice 2013-60, seeking to clarify prior guidance, Notice 2013-29, related to when a taxpayer has satisfied the requirements necessary to claim the renewable electricity production tax credit (PTC) under Section 45.

The IRS has issued guidance (Rev. Rul. 2012-19) on how dividends and dividend equivalents are treated for purposes of the $1 million compensation deduction limit under Section 162(m).

The sponsors of those plans are permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions are satisfied.

The IRS intends to amend regulations to provide guidance concerning the treatment of U.S. persons that own stock of a passive foreign investment company.

The IRS has issued guidance that responds to Historic Boardwalk Hall, LLC v. Commissioner, in which the Third Circuit held that an investor in a partnership who did not have any meaningful downside risk or upside potential was not a bona fide partner for federal tax purposes, and was therefore not entitled to an allocation of 99.9% of the historic rehabilitation tax credits under Section 47.