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.
Selling Partnerships That Own CFCs: A Potential Trap for the Unwary
Should gain recognized on a sale of a partnership that owns CFC stock be treated as capital gain or ordinary income?
Why the Internal Revenue Manual Is Valuable to Your Clients
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.
Wife of Anti-Tax Author Sentenced to Prison
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.
Understanding IRS Form 1099-K Letters and How to Quickly Respond
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 Procedures Designed to Restore Confidence in Appeals’ Independence, Improve Efficiency
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.
Guiding Clients Through the Offshore Voluntary Disclosure Program
This item provides a synopsis of the steps and procedures involved in initiating and completing a successful voluntary disclosure through the OVDP.
Final Regs. Provide Rules for Assessment Limitation Period for Undisclosed Listed Transactions
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.
Qualified Performance-Based Compensation Rules Are Finalized
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.
FIRPTA Rules Impact U.S. Real Estate Transactions
Prospective purchasers should be aware of withholding tax obligations and tax reporting requirements under the Foreign Investment in Real Property Tax Act.