IRS Written Determination on Portability Election Extension
The IRS has issued a written determination granting an extension of time for a decedent's estate to make a portability election. This election allows a surviving spouse to utilize the deceased spouse's unused exclusion amount for estate tax purposes. The determination addresses the specific circumstances under which such an extension was granted.
IRS Approval of Scholarship Procedures Under IRC Section 4945(g)(1)
The IRS has approved the scholarship procedures of a private foundation under IRC Section 4945(g)(1). This determination means that grants made under these approved procedures will not be considered taxable expenditures for the foundation and may not be taxable to the recipients if used for qualified educational expenses.
IRS Denies Tax Exemption Under IRC Section 501(c)(3)
The IRS has issued a final determination denying tax-exempt status to an organization under IRC Section 501(c)(3). The organization failed to submit a protest within the 30-day period following a proposed adverse determination. As a result, donors cannot deduct contributions, and the organization must file federal income tax forms.
IRS Denies Tax Exemption for 501(c)(4) Organization
The IRS has issued a final determination denying tax-exempt status to a 501(c)(4) organization. The organization failed to file a protest within the 30-day period following a proposed adverse determination. The IRS cited the organization's operations as a real estate management association funded similarly to a homeowners' association as the basis for denial.
IRS Written Determination: Extension of Time for Tax Elections
The IRS has issued Written Determination 202612008, granting an extension of time for a taxpayer to make a regulatory election to adopt a specific taxable year. The determination addresses the criteria for relief under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations.
IRS Written Determination: Extension for Entity Classification Election
The IRS has released a written determination granting an extension of time for a foreign eligible entity to file an election to be treated as a disregarded entity for U.S. federal income tax purposes. This determination addresses the application of § 301.9100-3 for late entity classification elections.
IRS Written Determination on S Corporation Reorganization and Equity Grants
The IRS has released a written determination (PLR-112688-25) addressing a corporate reorganization involving an S corporation and subsequent equity grants to employees. The determination clarifies the tax treatment of these transactions, particularly concerning the S corporation status and the issuance of shares under employee compensation plans.
IRS Ruling on Inadvertent S Corporation Election Termination
The IRS has issued a written determination addressing an inadvertent termination of an S corporation election due to late Qualified Subchapter S Trust (QSST) elections. The ruling grants relief under Section 1362(f), allowing the corporation to retain its S corporation status.
IRS Written Determination on Qualified Opportunity Fund Election Extensions
The IRS has issued a written determination granting relief under sections 301.9100-1 and 301.9100-3 for a taxpayer's late election to self-certify as a Qualified Opportunity Fund. The determination addresses the specific facts of a limited liability company that failed to file Form 8996 due to a misunderstanding of reporting requirements.
IRS Written Determination: Extension for Entity Classification Election
The IRS has released a written determination granting an extension of time for an entity (X) to file Form 8832, Entity Classification Election. The entity inadvertently failed to timely elect to be classified as an association taxable as a corporation for federal tax purposes.
IRS Final Rule on Nonpersonal Use Vehicle Substantiation
The IRS has issued final regulations defining qualified nonpersonal use vehicles. These regulations add unmarked vehicles used by firefighters or rescue/ambulance crew members as a new category of qualified nonpersonal use vehicles, exempting them from certain substantiation requirements. The changes affect governmental units and employees who use these vehicles.
IRS Corrects Estate Basis Reporting Rule
The IRS has issued correcting amendments to a final rule published in September 2024 concerning estate basis reporting under sections 1014(f) and 6035 of the Internal Revenue Code. These corrections address inadvertent overwrites in the previous language and are effective March 19, 2026.
IRS Updates to Form 8829 Instructions
The IRS has updated the instructions for Form 8829, used by taxpayers to calculate the deductible expenses for business use of a home. The updates clarify references on Line 11 and Line 17 of the form, specifically regarding student loan interest deductions and the use of the Line 11 Worksheet.
IRS Form 8850 No Longer in Use After 2025
The IRS has announced that Form 8850 will no longer be in use after December 31, 2025. This form was previously used to pre-screen employees for the Work Opportunity Tax Credit. The credit itself will not apply to employees beginning work after this date.
IRS Internal Revenue Bulletin 2026-13
The IRS published Internal Revenue Bulletin 2026-13, including proposed regulations on electronic furnishing of payee statements for digital asset sales by brokers and guidance on a new pilot program for child accounts. The bulletin also includes a notice requesting comments on modifying electronic furnishing requirements for brokers and other persons.