Newsletters

Government Employees Who Receive Returns or Return Information Subject to Disclosure Restrictions, Rev. Rul. 2022-7

The IRS has issued a guidance stating that government employees who receive returns or return information pursuant to disclosures under Code Sect. 6103(c), are subject to the disclosure restrictions, like all designees who receive returns or return information pursuant to taxpayer consent. Further, government employees who receive returns or return information pursuant to disclosures under Code Sec. 6103(k)(6) or (e), other than Code Sec. 6103(e)(1)(D)(iii) (relating to certain shareholders), are not subject to the disclosure restrictions with regard to the returns or return information received.

Background

Section 2202 of the Taxpayer First Act (TFA), P.L. 116-25, amended Code Sec. 6103(a)(3) and (c) to limit redisclosures and uses of return information received pursuant to the staxpayer consent exception. Code Sec. 6103(c), as amended by the TFA, explicitly prohibits designees from using return information for any reason other than the express purpose for which the taxpayer grants consent and from redisclosing return information without the taxpayer’s express permission or request. Further, Code Sec. 6103(a)(3), as amended by the TFA, imposes disclosure restrictions on all recipients of return information under Code Sec. 6103(c). The TFA did not amend Code Sec. 6103(e) or (k)(6), or Code Sec. 6103(a) with respect to disclosures under Code Sec. 6103(e) or (k)(6).

Disclosure Restrictions

The IRS cited seven situations where disclosure restrictions of Code Sec. 6103(a) would or would not be applicable with regard to returns or return information received as a result of disclosure under:

Effect on Other Documents

Rev. Rul. 2004-53, I.R.B. 2004-23, has been modified and superseded.

FL - Taxpayer properly applied cost-of-performance rule to its income producing activities

An out of state subsidiary (taxpayer) of a nationwide online and brick-and-mortar retailer (retailer) properly sourced its service revenue under […]

Read More
FL - Taxpayer properly applied cost-of-performance rule to its income producing activities

FL - Guidance provided on tax relief for properties made uninhabitable by Hurricanes Ian or Nicole

Florida provides guidance regarding property tax relief for residential properties rendered uninhabitable for 30 days or more due to Hurricanes […]

Read More
FL - Guidance provided on tax relief for properties made uninhabitable by Hurricanes Ian or Nicole

FL - Relief for corporate income taxpayers impacted by Hurricane Nicole discussed

Florida will follow the corporate income tax relief granted by the Internal Revenue Service (IRS) for Hurricane Nicole affected taxpayers […]

Read More
FL - Relief for corporate income taxpayers impacted by Hurricane Nicole discussed

Elizabeth Askey Appointed As New Deputy Chief Of IRS Appeals, IR-2022-219

The IRS Independent Office of Appeals has announced the appointment of Ms. Elizabeth Askey, an alumnus of Harvard Law School, […]

Read More
Elizabeth Askey Appointed As New Deputy Chief Of IRS Appeals, IR-2022-219

IRS Issues Guidance on Form W-4 Substitute Submissions, Additional Guidance for Substitute Submissions of Form W-4

The IRS stated that, for 2022, general guidelines for electronic substitutes to paper Forms W-4 can be found in the […]

Read More
IRS Issues Guidance on Form W-4 Substitute Submissions, Additional Guidance for Substitute Submissions of Form W-4

TIGTA Launches New Website

The Treasury Inspector General for Tax Administration (TIGTA), J. Russell George, announced a redesign of the agency’s website, to better serve […]

Read More
TIGTA Launches New Website

FBAR Filing Deadline Extended for Individuals with Signature Authority but No Financial Interest in Certain Accounts, FinCEN Notice 2022-1

The Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for certain individuals to file a Report of […]

Read More
FBAR Filing Deadline Extended for Individuals with Signature Authority but No Financial Interest in Certain Accounts, FinCEN Notice 2022-1

Courtney Kay-Decker Appointed as New Deputy Chief Taxpayer Experience Officer, IR-2022-222

The IRS has appointed Courtney Kay-Decker as the new Deputy Chief Taxpayer Experience Officer today. Kay-Decker will lead IRS efforts […]

Read More
Courtney Kay-Decker Appointed as New Deputy Chief Taxpayer Experience Officer, IR-2022-222

FL - Alachua County local government infrastructure surtax rate increased

Beginning January 1, 2023, the combined Florida state and local sales and use tax rate for Alachua County is 7.5%. […]

Read More
FL - Alachua County local government infrastructure surtax rate increased

FL - 2023 fuel tax rates announced

The 2023 Florida motor fuel, diesel fuel, and aviation fuel tax rates are announced. Annual adjustments to the state fuel […]

Read More
FL - 2023 fuel tax rates announced