On September 13, 2024, the Louisiana Department of Revenue (the “Department”) published Revenue Information Bulletin Number 24-019 granting automatic extensions to eligible individuals and businesses impacted by Hurricane Francine.
IRS Extends Filing Deadlines for Taxpayers in Louisiana due to Hurricane Francine
On September 13, 2024, the Internal Revenue Service (IRS) announced that taxpayers in Louisiana will have until February 3, 2025 to file various federal individual and business tax returns and make certain payments due to Hurricane Francine. The extension applies to any individual, business, or tax-exempt organization that has a valid extension to file their
IRS Provides Details of the Second Employee Retention Credit Voluntary Disclosure Program
The Internal Revenue Service (“IRS”) published details regarding the second Employee Retention Credit Voluntary Disclosure Program (the “Disclosure Program”) on August 15, 2024. The Disclosure Program will allow employers who previously received payments for their Employee Retention Credit (“ERC”) to repay 85% of the credit received.
FinCEN Confirms the CTA Does Not Require Disregarded Entities to Obtain an EIN
On July 24, 2024, FinCEN updated its Corporate Transparency Act FAQ section to confirm that disregarded entities may use their parent’s Employer Identification Number when filing Beneficial Ownership Reports.
FinCEN Corrects Employer Identification Number Issue for Single Member LLCs
After receiving complaints that disregarded entities required to file Beneficial Ownership Information (BOI) Reports could not do so using their parent’s Employer Identification Number (EIN), the Financial Crimes Enforcement Network (FinCEN) has corrected the issue.
New Revenue Ruling Aims to Root Out “Basis-Shifting Transactions”
On June 17, 2024, the IRS published Revenue Ruling 2024-14 as part of a package it says will raise an additional $50 billion dollars of income taxes over the next decade from “basis-shifting transactions.”
SCOTUS Holds that Life Insurance Proceeds Used to Finance Stock Purchase Agreements Do Increase the Value of Closely Held Corporations for Estate Tax Purposes
On June 6, 2024, the Supreme Court of the United States ruled that life-insurance proceeds required to be used to redeem stock of a deceased shareholder must be included in the value of the company for purposes of determining the deceased shareholder’s gross estate.
Treasury Finalizes Regulations for Requesting an Extension of Time to Make Certain GST Elections
On May 3, 2024, the Treasury Department finalized regulations for the extension of time to make certain elections pertaining to the Generation Skipping Tax (GST) including elections for exemption allocations under section 2642(g).
FinCEN BOI Reporting for Disregarded Entities Appears to Conflict with Existing IRS Regulations for Employer Identification Numbers
Since Treasury Regulation Section 301.6109-1(h)(2)(i) took effect in 1997, the Internal Revenue Service (IRS) has permitted disregard entities, including single member limited liability companies to use the Employee Identification Number (EIN) of its owner (unless the disregarded entity has employees). Unfortunately, and without any regulatory authority, the Financial Crimes Enforcement Network (FinCEN) is not permitting disregarded entities to use their owner’s EIN for purposes of beneficial ownership reporting.
IRS Seeks to Curtail Abusive Transactions Involving CRATs
On March 22, 2024, the Treasury Department published a proposed regulation relating to certain transactions involving Charitable Remainder Annuity Trusts (“CRATs”) investing in single premium immediate annuities (“SPIAs”). The rule would designate transactions seeking to exclude from income SPIA payments from a CRAT under Section 72(b)(2) of the Internal Revenue Code (the “Code”).