Tax Impacts

On July 25, 2025, the Internal Revenue Service (IRS or Service) released an Interim Guidance Memorandum dated July 23, 2025 (the IGM) that i) eliminates the Acknowledgement of Facts (AOF) Information Document Requests (IDR) from Large Business & International Division (LB&I) examinations, ii) provides updates on the changes to the Fast Track Settlements (FTS) pilot program, and iii) clarifies the applicability of Accelerated Issue Resolution (AIR) to Large Corporate Compliance (LCC) cases.

The year 2024 brought a breadth of noteworthy and significant tax decisions impacting both individual and corporate taxpayers. In the first of a recurring series, this article discusses tax cases from 2024 that we found intriguing and relevant to taxpayers.

On January 10, 2025, the Internal Revenue Service (IRS) and Treasury Department finalized regulations (REG-109309-22) that identify certain micro-captive insurance transactions, as well as transactions that are “the same as, or substantially similar to” those micro-captive transactions, as “listed transactions.”

On September 8, 2023, the IRS announced that it will start a “sweeping, historic effort to restore fairness in tax compliance” by focusing its attention on high-income taxpayers, partnerships, large corporations, and promoters.

On April 21, 2022, the Supreme Court of the United States held in Boechler, P.C. v. Commissioner that the 30-day time limit under Internal Revenue Code (“I.R.C.” or “Code”) § 6330(d)(1) for a taxpayer to file a petition for a collection due process (“CDP”) hearing with the United States Tax Court is a non-jurisdictional deadline. The Supreme Court’s holding is significant because, as a non-jurisdictional deadline, I.R.C. § 6330(d)(1)’s 30-day time limit would not prohibit the Tax Court from considering an untimely filed petition when appropriate.