Adrian JohnsonTLDR:
- Midpoint of 2024 marks significant developments in tax, including regulations, court cases, and agency pronouncements.
- Key elements include new regulations on charitable contributions, taxability of settlement proceeds, disaster payments, and taxation of home energy rebates.
In the first half of 2024, tax professionals have seen a range of developments that have implications for individuals, retirement and estate planning, and procedural matters. Some key highlights include:
Individuals:
- Final regulations under Code Sections 170 and 786 limiting charitable contributions from partnerships based on conservation easements have been issued.
- Court decisions have addressed the taxability of settlement proceeds, including the categorization as civil rights violations.
- The IRS has determined that payments made by Norfolk Southern to individuals affected by specific events are tax-free disaster payments.
Retirement and Estate Planning:
- Proposed regulations would classify certain transactions involving charitable remainder annuity trusts and single premium annuities as “listed transactions.”
- Court decisions have addressed the taxability of forfeitures, transfers within families, and contributions between related companies.
- The U.S. Supreme Court affirmed the constitutionality of the Mandatory Repatriation Tax under the Tax Cuts and Jobs Act of 2017.
Procedure:
- FinCEN proposed regulations that would require special record retention and submission of information on transfers related to residential real property to assist in identifying money laundering.
- Court decisions have impacted the deference given to IRS regulations and the civil statute of limitations in cases of fraud by preparers.
- The IRS has reminded taxpayers to be cautious when relying solely on AI-generated tax advice.
Overall, the first half of 2024 has been eventful in the realm of tax, with significant implications for individuals, retirement planning, and procedural matters. Tax professionals will need to stay updated on these developments as the year progresses.
