This is an Announcement that implements a pilot program testing changes to Fast Track Settlement (FTS) programs currently available to taxpayers under examination in the Internal Revenue Service (IRS) Large Business and International (LB&I), Small Business/Self-Employed (SB/SE) and Tax Exempt/Government Entities (TE/GE) Divisions. This Announcement also describes pilot program changes to Post Appeals Mediation (PAM) procedures and introduces a “Last Chance FTS” pilot program for SB/SE taxpayers. In this 2-year pilot, the primary changes to the current FTS programs include: (1) FTS may be used for a specific issue in a case rather than requiring all issues in a case to be eligible for FTS; and (2) PAM will be available for all taxpayers in the FTS programs. In addition, the “Last Chance FTS” pilot program is intended to further publicize availability of FTS and will initially be limited to select SB/SE cases.

This document contains proposed amendments to the regulations governing practice before the IRS. These regulations propose to eliminate provisions related to registered tax return preparers, classify the use of certain contingent fee arrangements by practitioners as disreputable conduct, establish new standards for appraisals and the disqualification of appraisers, and update certain provisions as appropriate.

These final regulations provide three rules regarding the timing of supervisory approval of penalties required under section 6751(b). The appropriate rule depends on the procedures the IRS must follow before it may assess a penalty. For penalties that are included in a pre-assessment notice that provides the basis for Tax Court jurisdiction upon timely petition, supervisory approval may be obtained at any time before the notice is issued. For penalties raised in Tax Court following a petition, supervisory approval may be obtained at any time prior to the Commissioner requesting that the court determine the penalty. For penalties that are not subject to pre-assessment review in Tax Court, supervisory approval may be obtained at any time prior to assessment. The regulations also include a list of penalties excepted from the requirements of section 6751(b), and definitions of the terms “immediate supervisor,” “designated higher level official,” “personally approved (in writing),” and “automatically calculated through electronic means.”

26 CFR 1.6751(b)-1

This notice provides temporary relief allowing eligible taxpayers to rely on alternative methods for making an adequate identification, within the meaning of § 1.1012-1(j)(3)(ii), with respect to units of a digital asset held in the custody of a broker.

This document contains proposed regulations regarding previously taxed earnings and profits of foreign corporations and related basis adjustments. The proposed regulations affect foreign corporations with previously taxed earnings and profits and their shareholders.