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The IRS concluded in an internal legal memorandum released Feb. 13 that a taxpayer’s nonrecourse liability affected its mark-to-market computation under Section 475(a).

The Organisation for Economic Co-operation and Development (OECD) on Oct. 5 released its highly anticipated final package on base erosion and profit shifting (BEPS) measures.

The IRS determined that payments received by automobile dealerships from automobile manufacturers under a facility image-upgrade program were income.

The IRS has issued proposed regulations (REG-151416-06) to revise regulations under Section 751(b) that have remained generally untouched since 1956.

Specifically, such treatment would apply to reporting, record maintenance and associated compliance requirements that otherwise apply to 25% foreign-owned domestic corporations under Section 6038A.

Republicans won a sweeping election victory last week, capturing the Senate and changing the landscape for tax legislation.

The taxpayer, Giant Eagle Inc., operates a chain of retail supermarkets, pharmacies, gas stations and convenience stores in the U.S. The taxpayer established a fuel rewards program in 1991.

Republican presidential candidate Mitt Romney offered new details on his tax plan before the first presidential debate last week.

The Supreme Court on May 20 ruled in "PPL Corp. v. Commissioner" that the one-time "windfall tax" imposed by the United Kingdom in 1997 had a predominant character of a "classic excess profits tax".

The taxpayer in Lamas sought to establish material participation to avoid passive characterization under Section 469.

The U.S. Tax Court held that a shareholder of several S corporations did not receive any basis in indebtedness to the S corporations merely from signing as a co-borrower on loans....

House and Senate Republicans have agreed on a conference report for their budget resolutions that would allow the tax-writing committees to use reconciliation procedures to expedite tax legislation.

In Neff v. Commissioner, T.C. Memo 2012-244 (8/27/12), the Tax Court addressed the tax consequences of the rollout of a split-dollar life insurance policy under guidance issued by the IRS under prefinal split-dollar regulations (T.D. 9092, 68 Fed. Reg. 54336 (9/17/03)) regarding the proper treatment of such policies applicable to split-dollar life insurance arrangements (SDLIAs) entered into after Sept. 17, 2003.

In Austin v. Commissioner, 141 T.C. No. 18, the Tax Court ruled that a forfeiture of stock upon termination for "cause," as defined in the company’s restricted stock agreement, constituted a substantial risk of forfeiture.

The IRS released its final report of audit results relating to its study of colleges and universities in April 2013.

The tax writing committees in both chambers have advanced bills that would address various IRS tax administrative rules and combat tax-related identity theft and fraud.

The new Republican-controlled Congress convened for the first time on Jan. 6, and Republicans in the House of Representatives immediately adopted a new rule for how to score tax legislation.