To help figure out all of the COVID-19 tax law changes enacted since March 2020, we have seen a variety of guidance from the IRS. This includes FAQs and some items just posted to an IRS website. These are non-binding items. Some guidance was published in the weekly Internal Revenue Bulletin (revenue rulings, revenue procedure, notices and announcements) so is binding on the IRS.
Since these changes mostly expired in less than one year, there wasn’t time for public comment and binding guidance for everything. Taxpayers and practitioners wanted insights as quickly as possible.
But what about other tax rules that are here for longer? Why aren’t regulations used more often particularly for unclear areas where public comments would be useful. For example, some of the information on taxation of virtual currency are FAQs or a revenue ruling where there was no public comments and there are issues as to whether the guidance is correct.
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