ArticleIRS Publishes Another IPU On Transfer PricingThe Internal Revenue Service (IRS) continues to publish International Practice Units (IPUs) on transfer pricing.United StatesTaxMcDermott Will & Emery
ArticleIRS Publishes Revenue Ruling On ‘North-South' SpinoffsIn Situation 1 of the Rev. Rul., Parent owns all the stock of Distributing, which owns all the stock of Controlled. On Date 1, Parent purports to contribute $25x of property of Controlled in...United StatesTaxGrant Thornton LLP
ArticleIRS Releases Guidelines For Speeding Up Audits Of Large BusinessesThe IRS has issued new guidance to its Large Business and International Division (LB&I) in an attempt to expedite audits.United StatesTaxHolland & Knight
ArticleIRS Releases Newly Revised Form 3115 And InstructionsThe IRS recently released a new version of the Form 3115, "Application for Change in Accounting Method," along with 23 pages of instructions.United StatesTaxGrant Thornton LLP
ArticleIRS Releases Safe Harbor For De Minimis Errors In Information ReportingIn Notice 2017-09, the IRS provided guidance on the safe harbor for de minimis and inadvertent errors in amounts reported on information returns.United StatesTaxGrant Thornton LLP
ArticleIRS Releases Sample Language For Section 83(B) ElectionsThe IRS has provided sample language (Rev. Proc. 2012-29) that may be used (but is not required to be used) for making an election under Section 83(b). United StatesTaxGrant Thornton LLP
ArticleIRS Renews Its Focus On High-Income TaxpayersAs part of the agency's efforts to reduce the "tax gap," the Internal Revenue Service (IRS) is signaling its intent to focus on high net worth individuals.United StatesTaxReinhart, Boerner, Van Deuren SC
ArticleIRS Response To COVID-19IRS Notice 2020-18, which supersedes a more restrictive Notice 2020-17, provides taxpayers with relief concerning income tax filings and payments otherwise due on April 15, 2020.United StatesTaxRhoades McKee PC
ArticleIRS Reverses Position On "Bad Boy" GuaranteesOn April 15, 2016, the IRS released Advice Memorandum 2016-001 reaching very different conclusions than those in the February CCA. United StatesTaxButler Snow LLP
ArticleIRS Says Check Your ITIN Renewal DateRenewing an ITIN is done by filing IRS Form W-7, including any required documentation.United StatesTaxEide Bailly LLP
ArticleIRS Signals Continued Enforcement With New Conservation Easement Settlement OfferThe Internal Revenue Service has announced plans to roll out a new settlement initiative aimed at reducing the significant backlog of conservation easement cases currently...United StatesTaxPolsinelli PC
ArticleIRS Tax Regulations And The 1 For 2 Trump Executive OrderAs a result, the IRS regulations may not be subject to the one for two rule.United StatesTaxAkin
ArticleIRS Teleconference on Voluntary Closing Agreement Program Highlights Focus on Written Post-Issuance Compliance ProceduresOn September 8, 2011, the Tax Exempt Bonds staff of the Internal Revenue Service (the "Service") hosted a teleconference to explain updates to its Voluntary Closing Agreement Program (VCAP), which allows issuers to voluntarily come forward to the Service with identified violations relating to its bonds and work towards a mutual resolution to correct the violation.United StatesTaxVinson & Elkins LLP
ArticleIRS To Discontinue Paper Processing In Near FutureThe IRS has announced that it will cease the processing of paper returns at three IRS campuses over the coming years. The three affected locations are Covington, Kentucky, Fresno, California, and Austin, Texas. United StatesTaxBrown Smith Wallace
ArticleIRS To Hire 700 For Civil And Criminal Tax EnforcementOn May 3, the Internal Revenue Service announced that it will be hiring between 600 and 700 new federal tax enforcement personnel.United StatesTaxCaplin & Drysdale, Chartered
ArticleIRS To Reject Checks With Amounts Greater Than $100 MillionThe IRS announced Sept. 7 that beginning in 2016, it would no longer accept checks in an amount of $100 million or more, citing an inability to process checks of that size. United StatesTaxGrant Thornton LLP
ArticleIRS Updates Rules Regarding Appeals ConferencesThe Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016:United StatesTaxMcDermott Will & Emery
ArticleIRS Will Not Acquiesce On Retroactive Rulings DecisionThe IRS has released an action on decision formally rejecting a 1966 Court of Claims opinion in "IBM v. U.S."United StatesTaxGrant Thornton LLP
ArticleIs Deferred Compensation Dead Under The Proposed Tax Bill?If the Tax Cuts and Jobs Act (the "Act") is enacted, as currently drafted, then it would kill non-qualified deferred compensation as we know it today.United StatesTaxSmith Gambrell & Russell