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.

The president has named Daniel Werfel the new acting IRS commissioner after Steven Miller resigned.

The president has signed into law a transportation funding bill (H.R. 4348) that extends current fuel taxes and raises new revenue with several pension and retirement plan provisions.

A U.S. district court ruled June 16 that a common parent of a consolidated group was not owed a refund from the IRS that was paid to the Federal Deposit Insurance Corporation (FDIC) as a fiduciary.

The IRS has proposed regulations (REG-153627-08) to amend the rules for automatic extensions of time for filing certain employee plan returns by adding Form 8955-SSA

The House and Senate approved a budget resolution last week that would allow them to repeal the Affordable Care Act (ACA) using the budget reconciliation process.

The Senate last week abandoned efforts to craft a broader tax package to be included with a reauthorization of the Federal Aviation Administration (FAA).

The tax reform working groups created by Senate Finance Committee Chair Orrin Hatch, R-Utah, have begun working toward legislative recommendations that Hatch wants ready by the end of May.

Under the facts of the FAA, the taxpayer, a motor freight carrier, would contract with independent truck operators to transport retail goods for third parties.

The Supreme Court on Jan. 14 heard oral arguments in United States v. Quality Stores (Ct. Dkt. No. 12-1408), which should settle whether supplemental unemployment benefits (SUB) made for involuntary termination are subject to Federal Insurance Contributions Act (FICA) tax.

The Supreme Court on Oct. 9 heard arguments in a case that could resolve a split in the circuit courts of appeal, of whether courts can apply an accuracy-related penalty for a tax underpayment that is attributable to a valuation misstatement, when the underlying transaction is disregarded for lacking economic substance.

An APA is an agreement between the IRS and a taxpayer on a transfer pricing methodology.