On Friday, September 2, 2011, the IRS announced its 2011-2012 Priority Guidance Plan.  The 2011-2012 Priority Guidance Plan lists 317 projects that the IRS intends to work on over the next year, including regulatory guidance for the Whistleblower Program under section 7623.

TAX ADMINISTRATION

33. Regulations under § 7623, as amended by § 406 of the Tax Relief and Healthcare Act of 2006, regarding whistleblower awards and the operation of the Whistleblower Office.

 

We suspect these regulations may be part of the broader guidance plan that the IRS alluded to in its hearing on the “collected proceeds” regulations last May.  We hope that these regulations will provide additional clarity on the IRS’s position a variety of issues such as net operating loss carryovers, credits, and timing of award payments. 

While inclusion on the Priority Guidance Plan does not place a deadline on the completion of the projects listed on it, the projects on the Priority Guidance Plan are the projects the IRS intends to work on actively throughout the plan year, July 2011 through June 2012.  We will keep you posted as additional guidance is released.

Lynam Knott