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The Treasury Department and the Internal Revenue Service (IRS) have finalized rules for reporting digital asset transactions performed by brokers. These new regulations, effective January 1, 2027, require brokers who regularly facilitate digital asset sales, like those in decentralized finance (DeFi), to provide forms reporting gross proceeds from these transactions. The rules primarily apply to trading front-end service providers, who are best positioned to report on such transactions due to their close interaction with customers. The regulations aim to enhance tax compliance by ensuring digital asset transactions are reported similarly to traditional financial trades.

The IRS and Treasury Department have finalized regulations that extend the time individuals have to roll over qualified plan loan offset amounts from 60 days to their tax filing due date (including extensions) for the year the offset occurs. This extension was established under the Tax Cuts and Jobs Act to help participants in employer-sponsored retirement plans who have an outstanding loan balance when they either leave their job or when their employer plan terminates. These regulations are effective from January 1, 2021, but individuals can choose to apply them to offsets deemed distributed on or after August 20, 2020. The regulations aim to simplify the process for taxpayers and provide clearer guidelines for plan administrators.

The Internal Revenue Service (IRS) and the Treasury Department have released final rules on determining taxable income and foreign currency gains or losses for businesses operating with a currency other than the U.S. dollar. These regulations clarify how businesses can elect to manage currency gains or losses annually and introduce a transition rule to make compliance easier. The rules apply broadly, including to specified entities like insurance companies, but do not currently extend to partnerships without additional guidance. These updates are aimed at providing clear and consistent guidelines for businesses dealing with multiple currencies.

The Treasury Department and Internal Revenue Service have issued final regulations addressing how certain taxpayers should report income and advance payments under an accrual method of accounting. These regulations, influenced by the Tax Cuts and Jobs Act, require that income be reported no later than when it is recorded in a taxpayer’s financial statement. The regulations also allow some taxpayers to defer reporting income from advance payments to the next taxable year, provided it matches the company's financial statement treatment. These rules aim to ensure consistency between tax reporting and financial accounting.

The final regulations under section 1061 of the Internal Revenue Code provide guidance on recharacterizing certain long-term capital gains as short-term capital gains for partnership interests connected to the performance of substantial services. These regulations clarify definitions, provide exceptions, and establish rules for calculating recharacterized gains, including exceptions for capital interests and purchases by unrelated parties. The regulations also introduce rules for how gains are calculated when selling an API, ensuring the correct application of section 1061 to prevent tax avoidance. Additionally, the regulations impose information reporting requirements for compliance.

The Treasury Department and the Internal Revenue Service (IRS) have issued new regulations clarifying when tax-exempt bonds are considered retired for federal tax purposes. These rules aim to unify previous guidelines and are important for state and local governments that issue such bonds. The regulations detail specific situations where bonds can be seen as retired, including significant modifications to bond terms or certain transactions like purchases by the issuer. These changes will take effect on December 30, 2025, but issuers have the option to apply the new rules starting December 30, 2024.

The document discusses corrections to Treasury Decision 9992, which was previously published in the Federal Register. This decision provides final regulations on determining if a qualified investment entity is controlled within the U.S., addressing how qualified foreign pension funds should be treated. These corrections are effective from December 27, 2024, and aim to fix specific language in 26 CFR part 1. The document details the changes made to ensure the accurate interpretation of tax rules concerning investment control.

The IRS has issued final regulations detailing how tax disputes are resolved by their Independent Office of Appeals, under the Taxpayer First Act of 2019. Generally, all taxpayers can use Appeals to settle tax disputes without court involvement, but there are exceptions, such as frivolous cases or disputes involving constitutional issues. These regulations also outline the procedural requirements, highlighting that disputes must be handled by the originating IRS office first, and clarifying that there is typically one chance for a case to be reviewed by Appeals. Additionally, special rules for certain situations, like cases with criminal implications, are defined, and specific procedural guidance is provided for requesting Appeals consideration.

The Internal Revenue Service (IRS) has issued final regulations to address uncertainties regarding the supervisory approval of penalties. These rules are meant to clarify when and how the IRS must obtain supervisor approval for penalty assessments, ensuring penalties are imposed correctly and consistently. Public comments were reviewed, but proposed changes to the timing and definitions related to these approvals were not adopted, as they conflicted with existing laws and policies. The rules will take effect on December 23, 2024, and are designed to prevent improper use of penalties while making the process more transparent for taxpayers.

The Internal Revenue Service (IRS) and the Treasury Department have issued final regulations regarding the recourse liabilities of partnerships and rules for related persons, effective December 2, 2024. These rules clarify how to allocate partnership liabilities among partners when there is overlapping economic risk of loss (EROL) and address scenarios involving tiered partnerships and related parties. The regulations also introduce an ordering rule to determine the application of different rules and allow partnerships to apply these changes to liabilities on tax returns filed after December 2, 2024, with consistent application to all partnership liabilities. Additionally, comments were requested on the potential need for further guidance regarding liability reallocations in specific transactions.