An overview of the final tangible property regulations and discussion of the procedural guidance and what taxpayers will need to consider in complying with the final regulations.
Should gain recognized on a sale of a partnership that owns CFC stock be treated as capital gain or ordinary income?
Understanding how IRS personnel are instructed to perform certain procedures can be valuable to practitioners. This item contains several key areas of the IRM that should be noted in tax practice.
A taxpayer was sentenced to 18 months in prison followed by one year of supervised release after being convicted of criminal contempt for failing to file amended tax returns as ordered by a judge and for filing a false income tax return.
Taxpayers that sell products or services online or accept payment cards for sales need to be aware of IRS notice letters relating to Form 1099-K.
New provisions of the Internal Revenue Manual affect not only IRS Office of Appeals procedures, but also how Examination develops its cases and how taxpayers access Appeals.
This item provides a synopsis of the steps and procedures involved in initiating and completing a successful voluntary disclosure through the OVDP.
The IRS issued final regulations regarding the exception to the general three-year assessment limitation period for listed transactions that a taxpayer did not disclose as required under Sec. 6011.
The IRS issued final regulations regarding the exception under Sec. 164(m)(4)(c) to the $1,000,000 deduction limitation for compensation paid by publicly held corporations to covered employees.
Prospective purchasers should be aware of withholding tax obligations and tax reporting requirements under the Foreign Investment in Real Property Tax Act.