Newsletters

IRS Provides New Procedures to Resolve S Corporation and QSub Election, Rev. Proc. 2022-19

A new revenue procedure provides taxpayer assistance procedures to allow S corporations and their shareholders to resolve frequently encountered issues without requesting a private letter ruling (PLR).

Correcting S Corporation and QSub Election Issues

The new procedure addresses issues that generally do not affect the validity or continuation of an S corporation election, or of an election to treat a S corporation subsidiary as a qualified subchapter S subsidiary (QSub).

The procedure also provides corrective relief procedures to allow taxpayers in some situations to retroactively preserve S elections that are invalid or terminated solely because of certain non-identical governing provisions. A non-identical governing provision is one that, on its own or as part of another governing provision, results in the S corporation having more than one class of stock and, therefore, losing its eligibility to be an S corporation.

The IRS will no longer issue PLRs with respect to certain principal purpose determinations regarding the one class of stock requirement, or comfort rulings regarding certain S corporation and QSub election issues.

Effective Date

The new procedure is generally effective on the date it is published in the Internal Revenue Bulletin.

Under a transition rule, if a taxpayer has a request for a PLR regarding a non-identical governing provision that is postmarked (or if not mailed, received by the IRS) after the procedure is published, the taxpayer has 45 days to notify the Associate Chief Counsel (Passthroughs and Special Industries) of its decision to either:

A taxpayer that fails to notify the IRS is deemed to choose to continue to pursue its pending PLR request.

Effect on Other Documents

Rev. Proc. 2013-30 and Rev. Proc. 2022-1 are amplified, and Rev. Proc. 2022-3 is amplified and modified.

Energy Credit Online Tool Now Available to Sellers, IR-2023-202

The IRS has announced that enrollment to the IRS Energy Credit Online tool is now open to the sellers of clean vehicles. The Energy Credits tool is available free of cost and will […]

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Energy Credit Online Tool Now Available to Sellers, IR-2023-202

IRS Offers Cybersecurity Tips, IR-2023-200

The IRS and Security Summit partners reminded taxpayers to remain vigilant against potential cybersecurity threats. As the National Cybersecurity Awareness Month is […]

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IRS Offers Cybersecurity Tips, IR-2023-200

IRS Cautions Against Charity Scams Amid Global Crisis, IR-2023-196

The IRS has issued a warning to taxpayers, advising them to be cautious of fraudulent solicitors who pretend to represent genuine charities. These […]

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IRS Cautions Against Charity Scams Amid Global Crisis, IR-2023-196

IRS Reminds IRA Owners of Tax-Free Charitable Transfer Option, IR-2023-215

The IRS has reminded individual retirement arrangement (IRA) owners, aged 70½ or older, of tax-free charitable transfers permitting senior citizens to contribute up to $100,000 annually to eligible charities […]

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IRS Reminds IRA Owners of Tax-Free Charitable Transfer Option, IR-2023-215

IRS Urges Taxpayers to Review Withholding, IR-2023-205

The IRS has urged taxpayers to promptly review their tax withholding to avoid surprises, whether in the form of significant refunds or balances due when filing taxes next […]

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IRS Urges Taxpayers to Review Withholding, IR-2023-205

Low and Moderate Income Taxpayers Can Save More through Saver’s Credit in 2024, IR-2023-222

The IRS has reminded low and moderate income taxpayers that they can save more for their retirement now through Saver’s Credit. This credit is available to taxpayers who are 18 years […]

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Low and Moderate Income Taxpayers Can Save More through Saver’s Credit in 2024, IR-2023-222

FL - Change in Collier County local communications services tax rates announced

Effective January 1, 2024, the Florida local communications services tax (CST) rates in Collier County are as follows: 2.1% in […]

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FL - Change in Collier County local communications services tax rates announced

FL - Guidance on credit for human milk fortifier manufacturing equipment issued

Florida issued guidance regarding a corporate income tax credit for manufacturing equipment purchased for the production of human breast milk […]

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FL - Guidance on credit for human milk fortifier manufacturing equipment issued

FL - Guidance on internship tax credit program issued

Florida issued guidance regarding the student internship credit program for corporate income taxpayers. The program has been renamed as the […]

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FL - Guidance on internship tax credit program issued

IRS Introduces Expanded Chatbot Technology to Assist Taxpayers with Underreporting Notices, IR-2023-78

The Service has introduced an expanded chatbot to promptly address inquiries of taxpayers receiving notices about possible underreporting of taxes. The new chatbot feature will assist taxpayers receiving CP2000 , CP2501 and CP3219A notices. This tech […]

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IRS Introduces Expanded Chatbot Technology to Assist Taxpayers with Underreporting Notices, IR-2023-78