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The Internal Revenue Service is continuing to expand the features within Business Tax Account (BTA), an online self-service tool for business taxpayers that now allows them to view and make balance-due payments.

Launched last fall, BTA is a key part of the agency’s service improvement initiative funded under the Inflation Reduction Act (IRA). When fully developed, BTA will allow many types of business taxpayers to check their tax history, make payments, view notices, authorize powers of attorney and conduct other business with the IRS.

With the latest expansion, an eligible business taxpayer can now use BTA to pay Federal Tax Deposits (FTDs) and see and make a payment on their full balance due, all in one place. The account is also now accessible in Spanish with more translations planned. 

BTA is a key part of the agency’s ongoing work to transform and modernize service at the IRS by offering a seamless and convenient digital experience. It’s also an important part of a wide-ranging initiative to reduce paper-based processes that hamper the IRS and frustrate taxpayers.

Who can use BTA now?

Business taxpayers who can activate and use their IRS business tax account include:

• A sole proprietor who has an Employer Identification Number (EIN) issued by the IRS.
• An individual partner or individual shareholder with both:
• A Social Security number or an individual tax ID number (ITIN).
• A Schedule K-1 on file (for partners, from 2012-2023; for shareholders, from 2006-2023).

Currently, a limited liability company that reports business income on a Schedule C can’t access Business Tax Account. Future access will be available for these businesses, as well as other entities including tax-exempt organizations, government agencies, partnerships, C corporations and S corporations.

What can business taxpayers do now?

Within BTA, business taxpayers can now:

• View and make a payment toward a balance due by using a bank account. This includes a payment on a return filed for the current year as well as late payments for past tax years and Federal Tax Deposits.

• Schedule a payment for any business day for up to a year and cancel a scheduled payment.
• View recently processed payments, including payments made through the Electronic Federal Tax Payment System (EFTPS) online, wire transfers, checks or money orders, and see if any payments were returned or refused.
• Store multiple bank accounts in their online “wallet” to manage tax payments.
• Request a tax compliance check.
• View the business name and address on file.
• Give account access to employees of the business.
• Register for clean energy credits (if eligible).
• View and download transcripts for various payroll, income and excise tax returns.
• Sole proprietors can now download business entity transcripts from their BTA account. The transcript shows entity information like business name, mailing address, location address and more for the Employer Identification Number on file.
• View and download select digital notices including:
• CP080: Reminder - We Have Not Received Your Return, Credits May be on Your Account.
• CP136: Annual Notification of Federal Tax Deposit (FTD) Requirements (Forms: 941, 941-SS).
• CP216F: Application for Extension of Time to File an Employee Plan Return – Approved.

What new features will be added to BTA in the future?

Future capabilities made available through funding from the IRA will enable access by all business and organizational entities and help the business tax account become a robust online self-service tool.

To set up a new business tax account, or for more information visit Business Tax Account.

Have an IRS Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

The IRS has released new proposed regulations on making and revoking certain foreign currency gain or loss elections. These new proposals withdraw 2017 proposed regs §1.954-2(g)(3)(iii) and (g)(4)(iii) and proposed §1.988-7(c) through (e) and repropose them with revisions. (Preamble to Prop Reg REG-111629-23, 8/19/2024).

The IRS received comments about the 2017 proposals from practitioners who noted that the language of §1.954-2(g)(3)(ii) is inconsistent with other CFC filing requirements, which generally must be filed by U.S. shareholders for the tax year of a CFC that ends with or within the U.S. shareholders' tax year. 

In response to those comments, the IRS has issued a new set of proposed regs.

These new proposals would revise Reg §1.954-2(g)(3)(ii) to provide that controlling U.S. shareholders could make a §1.954-2(g) election on behalf of a CFC by filing a statement, clearly indicating that the election has been made, with their original income tax returns for the tax years of the controlling U.S. shareholders in which or with which the tax year of the CFC ends.

Additionally, these proposed regulations withdraw 2017 proposed §1.954-2(g)(3)(iii) and (g)(4)(iii). The IRS' new proposals would provide that controlling U.S. shareholders revoke a §1.954-2(g) election on behalf of a CFC by filing a statement that clearly indicates the election has been revoked with their original income tax returns for the tax years of the controlling U.S. shareholders in which or with which the tax year of the CFC ends.

Under new Prop Reg §1.954-2(g)(3)(iii) and Prop Reg §1.954-2(g)(4)(iii), controlling U.S. shareholders would be precluded from revoking a §1.954-2(g) election made on behalf of a CFC (including an initial election) until six years after the year in which the election was made. Additionally, the new proposals would provide that if a CFC's controlling U.S. shareholders revoke a §1.954-2(g) election, they may not make a new §1.954-2(g) election on behalf of the CFC until six years after the year in which the previous election was revoked.

According to the IRS, this change to the revocation rules "would limit taxpayers from opportunistically making or revoking a §1.954-2(g) election." For example, this change would limit taxpayers' ability to selectively recognize certain foreign currency losses.

Other proposals contained in this NPRM include changes to 2017 proposed regs §1.988-7(c) through §1.988-7(e).

For example, new Proposed Reg §1.988-7(d) would provide that the election made pursuant to proposed §1.988-7(c) is subject to rules like those imposed on Code Sec. 475 elections. The election would be effective for the tax year for which it is made and all subsequent years. The new proposal would provide that a taxpayer may revoke the election only with the IRS' consent.

Generally, these proposed regulations would apply to tax years ending on or after the date final regulations are published in the Federal Register (the "finalization date").

Taxpayers can rely on these proposed regulations and the treatment of certain elections, or revocation of elections, made in earlier periods.

Have an IRS Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

The U.S. Treasury Department should scrap or revise significantly an anti-abuse rule for nonresident aliens who receive loans from foreign trusts, which was included in proposed regulations on how to report foreign trust transactions, the American Institute of Certified Public Accountants said in a letter published on July 15, 2024.

The AICPA said in its letter that the rule should be significantly revised in several ways if it cannot be eliminated entirely. The proposed rule would treat certain loans as distributions under IRC Section 643(i) that originate from foreign trusts and are granted to a nonresident alien who becomes a U.S. person within two years.

Section 643(I) Would Apply To The Outstanding Loan
Amount From The Date The Beneficiary Becomes A
U.S. Citizen Or Resident
"If The Loan Was Not A Qualified Obligation
As Of The Date That It Was Made"
Under The Proposed Anti-Abuse Rule.

Among the institute's recommendations were applying the rule only on a prospective basis, limiting the applicability of the rule to "only if the loan was made to an individual who was previously a resident alien for at least a three-year period, and if the loan was made within two years before the individual resumed his or her resident alien status."

Treasury issued these proposed regulations in May 8, 2024 which were designed to provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.

Have an IRS Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced on August 15, 2024 in IR-2024-211,

The Internal Revenue Service today announced the opening of the application period for the 2025 Compliance Assurance Process (CAP) program, which will run from Sept. 4 to Oct. 31, 2024. 

The IRS will inform applicants if they’re accepted into the program in February 2025.

Launched in 2005, CAP employs real-time issue resolution through transparent and cooperative interaction between taxpayers and the IRS to improve federal tax compliance by resolving issues prior to the filing of a tax return.

To be eligible to apply for CAP, applicants must:

• Have assets of $10 million or more,

• Be a U.S. publicly traded corporation with a legal requirement to prepare and submit SEC Forms 10-K, 10-Q and 8-K or a privately held C-corporation including foreign-owned. Privately held applicants will be required to submit audited financial statements prepared in accordance with U.S. Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards (IFRS) or another permissible method, as deemed appropriate by the IRS, specific to the taxpayer applying to the CAP program on an annual basis and unaudited financial statements on a quarterly basis.

• Not be under investigation by, or in litigation with, any government agency that would limit the IRS’s access to current tax records.

See highlights and updates for detailed information on revisions to the CAP program for 2025, including updates on Bridge Plus, an expansion of the applicant eligibility criteria, a new eligibility exception and a new form for international issues. General program information and the 2025 application details are available on the CAP webpage. 

Privately held C corporations that apply will have to furnish audited financial statements, and related-entity or parent-audited statements won't be acceptable, the IRS said.

The agency also said Thursday that new applicants for the 2025 program will have to submit the Form 14234-E cross border activities questionnaire with their application. Returning applicants are directed to file it 90 days after the end of the prior tax year and simultaneously with filing tax returns, the IRS said.

The IRS also said it will add a new exception to the closed/open year eligibility rule because of Inflation Reduction Act provisions. A tax year staying open solely because of an outstanding Inflation Reduction Act  issue won't be deemed an open-filed return on the first day of an applicant's CAP year for purposes of program eligibility standards for returns, the agency said Thursday. President Joe Biden signed the tax and climate act into law in 2022.

Want To Avoid a IRS Tax Problem?

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog