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IRS Explains FSA Substantiation Rules
Groom Law Group
[Guidance Overview] May 11, 2023 "These rules are not new, so it is not clear why there was a need for the [Chief Counsel Memorandum] at this time. The issuance of this CCA might signal that the IRS is beginning to educate auditors on the substantiation rules and the tax consequences of not complying with these rules.... [A frequent question] is whether it is necessary to substantiate very small expenses, such as those in the $5 or less range. Based on this and earlier IRS guidance, the answer from the IRS' perspective is yes." |
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