In a recent Internal Legal Memorandum to the field, the IRS National Office determined that an aircraft was held for productive use in a trade or business for purposes of applying the Section 1031 nonrecognition provisions.

The IRS postponed the new asset value reporting requirements for estates until Feb. 29, 2016.

The IRS is requesting comments on a proposed revenue procedure, which, if finalized, would provide automatic consent to certain tax accounting method changes for revenue...

The IRS recently issued proposed regulations to provide guidance on the new rule that limits compensation deductions for health insurance providers to $500,000 per employee.

The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.

The IRS issued final regulations (TD 9773) on June 29, 2016, that will require U.S. multinationals with more than $850 million in revenue to report specific information on a CbC basis.

The IRS provided guidance on the changes to the funding stabilization rules for single-employer pension plans that were made by the Highway and Transportation Funding Act of 2014.

The IRS ruled in a chief council advice memorandum (CCA 2015-22-005) that a corporate officer of a common parent of a consolidated group must sign Form 2848...

The IRS has released draft instructions for trusts, estates and individuals to calculate and pay their Section 1411 net investment income (NII) tax liability and for partnerships and S corporations to report information on NII to shareholders and partners.

The IRS has issued Rev. Proc. 2013-12 to provide updated guidance on the voluntary correction program for employee retirement plans.

Electronically filed information returns are due by March 31, but with extensions, these returns may be due by the end of May.

The IRS has renewed its attack on the transfer tax planning technique in which taxpayers make installment sales to intentionally defective grantor trusts

While the IRS has not released official guidance on the changes, several senior LB&I officials have offered remarks publicly on the restructuring.

Treas. Reg. Sec. 1.263A-1(b)(13) provides that the origination of loans is not considered the acquisition of property for resale.

The IRS has ruled in PLR 2013-06-004 that an S corporation's distribution agreement with its shareholders would not create a second class of stock under Section 1361(b)(1)(D).

The IRS has ruled (PLR 2012-29-007) that an S corporation’s rental income is not passive income under Section 1362(d)(3)(C)(i).

The IRS said in a private letter ruling that a transfer of assets to a corporation by its sole shareholder constituted a transaction under Section 351, notwithstanding that the corporation would distribute assets to its shareholder prior to that contribution.

The Large Business & International division (LB&I) has issued a directive (LB&I-04-0814-007) to examiners that provides guidance in determining whether a taxpayer’s method for allocating mixed service costs (MSC) to certain self-constructed tangible personal property is appropriate and should not be challenged.

The IRS recently released its annual guidance for taxpayers requesting letter rulings, and it adds three areas under Section 355 for which the IRS will no longer issue letter rulings.

House Speaker Paul Ryan, R-Wis., promised last week that House Republicans would produce an outline for comprehensive tax reform by June.