Overview
Anti-Injunction Act Bars Suit Challenging IRS Reporting Rule and Penalty: The U.S. Court of Appeals for the District of Columbia Circuit ruled that a suit filed by two bankers associations challenging the legality of a Treasury regulation imposing a “penalty” on U.S. banks that fail to report interest paid to certain foreign account-holders is barred by the Anti-Injunction Act.
IRS Releases Guidance on Treatment of 2014 Biodiesel Mixture and Alternative Fuel Credits: Today the IRS released Notice 2015-56 informing claimants about the federal income tax treatment of credits under section 6426(c) and (d) that are paid in cash under the one-time claim submission process of section 160(e) of the Tax Increase Prevention Act of 2014 and implemented by Notice 2015-3. Specifically, a claimant must reduce its income tax deduction for (or cost of goods sold deduction attributable to) section 4081 excise taxes (or, if applicable, section 4041 excise taxes) for each calendar quarter during 2014 by the amount of the section 6426(c) biodiesel credit (or, if applicable, section 6426(d) alternative fuel credit) for fuel mixtures sold or used during that calendar quarter.