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IRS guidance and key appointments set the stage for 2025

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Year’s end is fast approaching for preparers and taxpayers alike, making the regulatory clarity from the Internal Revenue Service’s November wave of guidance a welcome addition across the profession. But with notable tax figures set to bow out in the face of new appointees, experts are awaiting the full brunt of changes to come.

One such announcement is President-elect Donald Trump’s nomination of former U.S. Representative Billy Long as the next commissioner of the IRS. “Since leaving Congress, Billy has worked as a business and tax advisor, helping small businesses navigate the complexities of complying with the IRS rules and regulations. … Taxpayers and the wonderful employees of the IRS will love having Billy at the helm,” Trump said in a Truth Social post this month.

Danny Werfel, who was nominated to the position by President Joe Biden last year, said he was ready to stay in the role for the remainder of his term, which is slated to end on Nov. 12, 2027. According to the conditions of the role, however, he serves at the pleasure of the sitting president.

The IRS has launched numerous campaigns under Werfel’s tenure, ranging from reclaiming more than $1 billion in delinquent taxes from millionaires to the addition of payments and Spanish translations to Business Tax Accounts.

“While much more work remains for the IRS to get where it needs to be, there should be no doubt the agency has accomplished many things during the past two years,” Werfel said in a statement. “These efforts to serve taxpayers and improve tax administration will continue to intensify and accelerate in upcoming months and into the future.”

Read more: Two years in: IRS highlights improvements under IRA

David Samuel Johnson is another new face, whose nomination to succeed the late J. Russell George as the next Treasury Inspector General for Tax Administration was approved this month by the Senate Finance Committee. 

If confirmed, Johnson said during his November confirmation hearing that a core focus of his would be to “provide candid, reliable and pertinent information to Congress, the Treasury Secretary and the IRS Commissioner” to improve the agency’s operational efficiency.

Trump has been active since Nov. 6 in making nominations for various positions with influence over the accounting space, including Paul Atkins to replace outgoing Securities and Exchange Commission Chairman Gary Gensler.

Read more: IRS reforms bring relief, but Trump win clouds future plans

Learn more about the recent noteworthy guidance and final rules published by the IRS last month and how filing benchmarks have changed accordingly.

The IRS headquarters in Washington

IRS phasing in new Form 1099-K thresholds

The Internal Revenue Service is helping ease the transitory burden of its Form 1099-K information reporting threshold by issuing Notice 2024-85 last month, setting the benchmark at $2,500 for 2025.

The previous $20,000 and 200 transaction threshold was originally cut to $600 by the American Rescue Plan Act of 2021, prompting outcry from taxpayers and professionals regarding the potential flood of forms. The IRS quelled these worries by gradually rolling out the new threshold, starting with establishing a $5,000 threshold for the 2024 calendar year.

“There are a variety of examples throughout history where the IRS — to protect taxpayers from undue burden or from potentially being overtaxed — where we have either delayed implementation or ramped implementation,” IRS Commissioner Danny Werfel said during a congressional hearing in February.

Read more: IRS phases in Form 1099-K threshold at $2,500 in 2025

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Chris Ratcliffe/Bloomberg

IRS issues final regs on clean energy partnership credits

The IRS published its final regulations last month for assisting entities that co-own clean energy projects with accessing clean energy tax credits through elective pay.

Set to take effect on Jan. 19 of next year, the new rules allow elective-pay-eligible entities ranging from state and local governments to churches and nonprofit organizations to utilize incentives by deeming specific clean-energy credits as refundable. 

The regulations go on to further clarify how eligible organizations can remain compliant when jointly investing in clean energy projects, as well as add further adjustments to how such projects can classify themselves to not be treated as partnerships and take advantage of elective pay.

Read more: Final regs issued for clean energy partnership credits

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R&D Credit claim revision period extended

The transition period for filers revising research and development tax credit claims has been extended through Jan.10, 2026.

The new process, which allows taxpayers 45 days to fine-tune their research credit claim being submitted for refund prior to the IRS’s final decision, comes from an October 2021 initiative to cut down on dubious filings. 

The changes require taxpayers to provide the IRS with information regarding the business components to which the Section 41 research credit claim relates for that year, all research activities performed for each business component and the total qualified employee wage expenses, total qualified supply expenses and total qualified contract research expenses for the claim year. These rules apply for any claims posed after June 18 of this year.

Read more: IRS extends R&D tax credit transition period

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IRS to accept duplicate dependent returns with IP PIN

Beginning in the 2025 filing season, the IRS will start accepting electronically filed tax returns claiming dependents featured on another taxpayer’s return, provided the second taxpayer uses a valid Identification Protection Personal Identification Number.

The agency will begin taking Forms 1040, 1040-NR and 1040-SS starting next season, helping cut down on the time between when the IRS receives the forms and when reimbursements are distributed — all while preserving the level of security against identity theft risks.

E-filed returns claiming duplicate dependents will continue to be rejected unless a valid IP PIN is provided.

Read more: IRS to accept duplicate dependent returns with an IP PIN

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401(k) limit increases, IRA limit stays the same

The IRS has raised its contributions cap for individual 401(k) plans for the 2025 tax year to $23,500 as part of its annual cost-of-living adjustments, while the $7,000 individual retirement account limit remains unchanged.

Guidance issued last month that outlined numerous cost-of-living adjustments highlighted how employees with 401(k), 403(b), governmental 457 plans and the federal government’s Thrift Savings Plan benefit from the increase. Both the annual contribution limit and catch-up contribution limits for IRA plan participants aged 50 and older remain constant at $7,000 and $1,000 for 2025, even with the latter adjusted under the SECURE 2.0 Act of 2022.

Read more: IRS increases 401(k) limit, keeps IRA limit the same

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Accounting

It’s never too late for year-end tax planning

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2024 brought a variety of ups and downs to the U.S. stock market, job market, and individuals’ pocketbooks and financial plans. 

The year started with volatility driven by inflation, interest rate adjustments by the Federal Reserve, economic uncertainty, and geopolitical issues. Yet the second half of 2024 has seen some stabilization as inflation receded and the Federal Reserve started to signal a pause in interest rate increases. 

However, what does not change is that we need to help our clients navigate their taxes and provide guidance for their financial future amidst the backdrop of uncertainty. 

As we approach 2025, now is an important time to sit down with clients to review their goals and do specific year-end planning to help them keep more of what they earn. We have put together a helpful guide to have productive conversations with clients about maximizing retirement contributions, considering tax-smart investment strategies to reduce their tax burden and more. 

Maximizing retirement contributions

Whether it is a 401(k) or a SIMPLE IRA, workplace retirement plans are a great option for clients to reduce their taxable income and save more of what they earn for their retirement. You should highly encourage your clients to participate in the employer-offered retirement plan. 

If the employer offers a retirement contribution match, clients should try to at least contribute enough to receive the full match. To harness the most tax-efficient elements of the plan, clients should max out the retirement plan, which reduces their overall taxable income. The 401(k)-employee contribution limit in 2024 is $23,000, but those 50 and older can contribute up to $30,500. The employee contribution limit for a SIMPLE IRA in 2024 is $16,000.   

Tax-smart investment strategies

End-of-year financial reviews should provide an outline of the gains and losses in your clients’ portfolios. This may identify opportunities for tax-loss harvesting. Tax-loss harvesting is when capital losses from one investment are used to offset taxes owed on capital gains from another investment or personal income. 

There are restrictions on the amount you can deduct from personal income taxes due to tax-loss harvesting; however, this could be something to consider if a client navigated several capital losses this year. 

Understanding their tax bracket

Work with your clients so they understand where they fall in their tax bracket to determine the most ideal strategies for them. For example, if your client is on the cusp of a higher tax bracket, are there tax-smart strategies that they should consider to stay below that higher tax bracket?

Questions to ask your clients:

  • Are they planning to sell an asset that would be subject to a capital gains tax? These are taxes that a client could pay on profits made from the sales of an asset like real estate or stock. If your client owned an asset for less than a year, they may owe a short-term capital gains tax depending on their tax rate. If this is the case, you can recommend that they hold onto the asset for longer to reduce their tax burden. On the other hand, if they owned something for more than a year, they may owe a long-term capital gains tax. You might consider investigating tax-loss harvesting opportunities. 
  • Are they invested in their employer’s health savings account or flexible spending account? These accounts set aside money from a client’s paycheck prior to taxes, which will lower their taxable income. 
  • Are there opportunities to defer a payment or a payout from a sale of an asset, collection of severance or other incoming money? If your client was laid off and is collecting a severance or sold a large asset of value (real estate, stocks, etc.), that income amount might push them into a higher tax bracket. It would be beneficial to decide now if they should split those payments between two years if it would lower the overall tax burden.
  • Do they expect to have income from investments? If so, they might be liable for a 3.8% net investment income tax on the lesser of their net investment income. Net investment income includes, but is not limited to interest, dividends, capital gains, rental and royalty income, and non-qualified annuities.

Consider opportunities to give back

This is a great time of year to discuss with clients causes that are important to them and if they want to provide a monetary contribution — whether financial, stocks, or a high-value item for donation. Open conversations about donations can uncover opportunities that may be eligible for a federal tax deduction. If your client is interested in donating directly to a charity of their choice in a donor-advised fund, it will only be deductible if they itemize and exceed the standard deduction. 

If your client is interested in donating directly to a charity, they may consider a qualified charitable distribution. This is a tax-free transfer of money from an IRA to a charity. Normally, a traditional IRA distribution is taxable; however, a QCD is tax-free as long as it is transferred directly to a charity. This option is available for individuals over 70½ years of age or older. The maximum amount that can be transferred through a QCD is $100,000. A QCD can provide several tax benefits. QCD can count toward required minimum distributions of a client’s IRA, therefore, reducing their taxable income. 

A donor-advised fund is a charitable investment account focused on supporting charitable organizations your clients care about. If your client contributes either cash or other assets to a DAF, they could take an immediate tax deduction. Keep in mind that some clients may want to start their own charitable fund, or support a 501(c)(3) organization’s DAF. In addition, as they decide on what organizations to support, those funds can grow tax-free and benefit the charitable organizations in the future. 

Start conversations about the TCJA sunset

The 2017 Tax Cuts and Jobs Act instituted significant Tax Code changes that reduced taxes for many individual investors; however, these tax cuts are only temporary. The TCJA is set to expire at the end of 2025 unless Congress decides to take action. 

Your clients may have seen tax cuts due to the TCJA and if they have, it will behoove you to have transparent conversations with them about how to navigate the TCJA expiring in 2025 and the potential tax increases they could see. 

The most significant tax cuts in the TCJA included: 

  • Federal individual income tax rates generally decreased;
  • Many itemized deductions were capped or disallowed;
  • The standard deduction doubled;
  • Changes to the Alternative Minimum Tax rules decreased the number of individual taxpayers subject to the AMT;
  • The gift and estate tax exemption doubled; and,
  • The qualified business income deduction was introduced.

Although how Congress will address the TCJA sunsetting in 2025 is unknown, it is critical for you to understand how the TCJA impacted your clients to help them determine how they will or will not be affected. As you have conversations with clients during year-end planning, here are areas to consider: 

  • Income tax planning: Take a look at your clients’ federal income tax rates now compared to 2017 and see if they were higher. Then review the AMT and check to see if your clients may qualify for that under pre-TCJA rules. Understanding if your clients will have a higher income tax or be subject to the AMT under pre-TCJA rules is important for them to know ahead of time and discuss potential income deferral strategies — especially for retirees who are navigating distributions or Roth conversions. 
  • Standard deduction: If your clients currently claim the standard deduction under TCJA, but they used to itemize, you may start flagging for them that they should consider itemizing for 2026 and the best ways to do that. 
  • Gift and estate planning: Currently, the enhanced gift and estate tax exemption is $13.61 million, but this will be cut in half after 2025 if the TCJA expires. You should have open discussions with your high-net-worth clients if they are considering making large gifts and if they want to use this exemption. Keep in mind, many wealth transfer strategies like the creation of trusts or real estate transfers require time to fully implement. If you have these conversations with clients now, they’ll be able to stay in front of potential changes and hopefully avoid any delays.

Help your clients keep more of what they earn

Having transparent and open year-end financial planning conversations now with your clients will help them get a head start on the coming year, identify goals, and determine the right strategies for their unique situation. It will also give you more opportunities to collaborate with financial advisors, estate attorneys, and other professionals to navigate the more complicated issues.

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Accounting

The 2024 Top 100 People: Work-life balance — myth or reality?

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Is it possible to strike a harmony between the professional and personal? The Top 100 Most Influential People have various views on the subject, based on their experiences ascending in their careers. 

We asked this year’s Top 100 People: “Do you feel you have work-life balance? If so, how have you achieved it?” and they shared their thoughts, as well as some advice for how to better walk that tightrope between home and office obligations. 

(To see the full responses of all the candidates for the Top 100, click here. And to see who the Top 100 voted the most influential, see here.)

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Accounting

In the blogs: On the horizon

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Crypto’s future; sobering CTC; inside and outside; and other highlights from our favorite tax bloggers.

On the horizon

  • Withum (https://www.withum.com/resources/): President-elect Trump has proposed several projects to boost the crypto sector, including dispensing capital gains tax for Bitcoin transactions and building a centralized Bitcoin holding account (a strategy reminiscent of America’s domination during the dot-com years). More clearly governed and with the support of the government, the crypto market could significantly increase in 2025.
  • Tax Vox (https://www.taxpolicycenter.org/taxvox): In 2025, the Tax Policy Center estimates that 17 million children younger than 17 will receive less than the full value of the Child Tax Credit because their parents earn too little. Most of these children also live in families that earn at least $2,500, the required minimum for any CTC beyond taxes owed. Congress has options when it debates the future of the CTC.
  • Institute on Taxation and Economic Policy (https://itep.org/category/blog/): As Congress negotiates federal funding during the lame-duck session, lawmakers would be wise to remember that stripping funds from the IRS costs more than it saves. 
  • Dean Dorton (https://deandorton.com/insights/): Next year could be a big one for the M&A market. A look at key metrics good and bad, from lower borrowing costs and thawing credit to valuation gaps and regulatory scrutiny.
  • Avalara (https://www.avalara.com/blog/en/north-america.html): Canada gets ready to “join the sales tax holiday fun.”
  • Sikich (https://www.sikich.com/insights/): Sikich has entered into an agreement to acquire the federal contracts of Cherry Bekaert Advisory LLC supporting the U.S. Patent and Trademark Office. 
  • HBK (https://hbkcpa.com/insights/): Reclassifying cannabis to Schedule III could expand access to banking, insurance, and other services for cannabis businesses. It may also ease the financial burden of Sec. 280E, which prohibits cannabis companies from taking standard business deductions due to marijuana’s current Schedule I status.
  • U of I Tax School (https://taxschool.illinois.edu/blog/): Interesting note on the beneficial ownership information reporting suspension: It invalidated much coursework and time in many tax schools this fall.

Good moves

  • Taxing Subjects (https://www.drakesoftware.com/blog): Preparing for the real season coming in the spring, from more IRS notices to high-net-worth clients to using artificial intelligence responsibly in your practice.
  • Canopy (https://www.getcanopy.com/blog): The importance of accountant-client privilege, the challenges in this age of technology and complex regulations, and how an accounting-based CRM platform is fundamental.
  • Turbotax (https://blog.turbotax.intuit.com): The “Moves That Matter” series kicks off with Drew, a lover of the outdoors from Montana. Interesting model in how to write a customer profile.
  • MBK (https://www.mbkcpa.com/insights): Estate planning is in many ways a big contingency plan. What about contingency plans for the beneficiaries?
  • Gordon Law (https://gordonlawltd.com/blog/): ‘Tis the season to tell them to stop sputtering: Why are bonuses taxed so heavily?

Virtual realities

  • Virginia – U.S. Tax Talk (https://us-tax.org/about-this-us-tax-blog/): How the “Bitcoin Jesus” now finds himself in a legal maelstrom after being arrested in Spain on U.S. charges of mail fraud, tax evasion and filing false returns.
  • Don’t Mess with Taxes (http://dontmesswithtaxes.typepad.com/): As internet betting continues to explode, a look at suggested tax rates of 15% to 25% of gross gaming revenue for new states where those feeling lucky can put their money down with a click.
  • TaxConnex (https://www.taxconnex.com/blog-): Holiday shopping season offers probably the year’s golden chance for your online biz clients, not only through sales on their own sites but also through household-name marketplace facilitators like Amazon. The glistening-once-again season also offers a big danger for your clients to ignite economic sales tax nexus.

Lowering the barter

  • Tax Foundation (https://taxfoundation.org/blog): The combined effect of net smuggling of cigarettes into U.S. states was a loss of more than $4.7 billion in forgone excise tax revenue in 2022. The annual effect of cigarette smuggling is significant, but the cumulative impact of annual smuggling from 2007 to 2022 demonstrates the severity of the issue when left to fester.
  • Mauled Again (http://mauledagain.blogspot.com/): “Analyzing the Federal Income Tax Consequences of a Crappy Barter Proposal.” Heavy on the “crappy.”
  • John R. Dundon II EA (http://johnrdundon.com/blog/): What to remind clients in biz partnerships about the difference between inside and outside basis. 
  • Boyum & Barenscheer (https://www.myboyum.com/blog/): What to remind biz-owner clients about the good and bad of retained earnings.

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