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.
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.
Indiana: Where Market-Based Sourcing and Income-Producing Activity Collide
The Indiana Department of Revenue has blurred the edges of two approaches to sourcing sales to create a potential trap for the unwary, opportunity for the savvy, and fertile ground for litigation.
Payments to Egg Donor Not Excludable From Income
The Tax Court ruled that a woman who received payments for undergoing the procedures necessary to donate her eggs could not exclude the payments from gross income as damages for personal injuries or physical sickness under Sec. 104(a)(2).
Taxpayer Was a Bona Fide Resident of U.S. Virgin Islands
Taxpayer who had filed tax returns with the U.S. VIBIR was a bona fide resident of the U.S. Virgin Islands, and the statute of limitation on assessment had expired on the U.S. returns.
Volunteering at Low Income Taxpayer Clinics Can Provide CPAs Valuable Experience
Volunteering for a Low Income Taxpayer Clinics pro bono panel gives a CPA a chance to provide valuable community service outside busy season and obtain additional experience in tax representation.
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.
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.