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The IRS filed a petition for "certiorari" on May 31 asking the Supreme Court to review the Sixth Circuit’s ruling in "United States v. Quality Stores".

In a field attorney advice memorandum (FAA 20134301F), the IRS analyzed an employer’s tax deduction timing related to bonuses paid to employees.

The IRS concluded that a taxpayer’s gain from the sale of a debt instrument was characterized as ordinary because it was a recovery of a prior bad debt deduction under Section 166.

The IRS issued a revenue ruling (Rev. Rul. 2015-09) on May 5 that addressed certain corporate step transaction issues and revoked a prior revenue ruling with similar facts (Rev. Rul. 78-120).

The IRS has postponed new rules that were scheduled to take effect in 2013 and will eventually expand corporate and broker basis reporting requirements.

The IRS Large Business and International Division (LB&I) has announced (LB&I-04-0812-010) that it will no longer use its "tiered issue process" to manage audit issues.

The IRS announced in Rev. Proc. 2013-22 that it will start accepting applications for opinion and advisory letters for both prototype and volume submitter Section 403(b) plans on June 28, 2013.

In 2015, Congress amended the due dates by which businesses must file tax returns, effective for tax years beginning after Dec. 31, 2015.

The IRS concluded in a chief counsel advice (CCA) memorandum that indemnification obligations related to originated mortgages did not constitute a security subject to Section 475.

The IRS has issued final regulations for determining whether disregarded entities can be considered the "taxpayer" for the bankruptcy and insolvency exceptions to cancellation of debt income rules.

The IRS has issued guidance providing a safe-harbor for determining whether certain debt constitutes qualified real property business indebtedness under Section 108(c)(3).

The IRS provided guidance on how certain provisions of the Patient Protection and Affordable Care Act apply to health reimbursement arrangements, health flexible spending arrangements and certain other employer health care arrangements.

The IRS has issued proposed regulations under Section 453B relating to the nonrecognition of gain or loss on certain dispositions of an installment obligation.

The IRS has issued temporary and proposed regulations (T.D. 9592 and REG-107889-12) adopting a bright line test for determining whether a foreign corporation satisfies the substantial business activities test of Section 7874(a)(2)(B)(iii) to avoid treatment as an inverted corporation.

The IRS issued temporary regulations under Treas. Reg. Sec. 1.337(d)-3T (T.D. 9722) that are intended to prevent corporate taxpayers from using a partnership to circumvent gain...

A recently released IRS program manager technical assistance (PMTA) memorandum (PMTA 2014-018) is a reminder of the importance of timely and complete filing of international information returns.

The IRS has proposed regulations under Section 4980H on a large employer’s responsibility to provide health insurance coverage to employees.