The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago.
The final regulations, which include 24 exceptions to consideration of federal tax controversies by the Independent Office of Appeals, generally follow the proposed regulations issued in October 2022.
New pilot programs involve fast-track settlements and post-appeals mediation.
The regulations provide guidance on determining who is one of the “five highest compensated employees” under Sec. 162(m)(3)(C).
The IRS said it used feedback from tax advisers to write the proposed regulations, which include new multiyear tax reporting requirements.
The final regulations, posted by the IRS on Tuesday in the Federal Register, identify certain microcaptive transactions as reportable listed transactions or transactions of interest.
The proposed regulations provide guidance to plan administrators on implementing the automatic enrollment requirement established by the Secure 2.0 Act.
In response to the Justice Department’s application for a stay of a district court injunction related to beneficial ownership information reporting, the plaintiffs claim that staying the injunction would harm reporting companies more than it would help the government.
IRS Commissioner Danny Werfel said he expects the 2025 filing season to build on the success of the two previous seasons if Congress maintains funding.
The proposed regulations apply to catch-up contributions under a 401(k) or similar workplace retirement plan that generally are allowed for workers who have attained age 50.