When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether...more
4/23/2019
/ Appeals ,
Capital Investments ,
Debtors ,
Encumbrances ,
Heirs ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Liens ,
Notice Requirements ,
Tax Debt ,
Tax Liability
Most tax professionals are aware of the common-law “mailbox rule,” which provides that proof of proper mailing creates a rebuttable presumption that the document was physically delivered to the addressee. Internal Revenue...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
4/18/2019
/ Arms Length Transactions ,
Audits ,
Base Erosion Tax ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Entities ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Banks ,
Offshore Funds ,
Transfer Pricing
We have written in the past about the Taxpayer Advocate Service (TAS), which is an independent organization within the Internal Revenue Service (IRS) whose job is to ensure that every taxpayer is treated fairly and knows and...more
Each New Year, many of us look back on the previous year’s activities, and determine what we want to accomplish in the coming year – lose weight, start exercising, read more tax articles, etc. The Internal Revenue Service...more
On March 2, 2018, President Trump nominated Michael Desmond to be the Chief Counsel of the Internal Revenue Service (IRS). Unfortunately, the Senate did not get around to confirming him. On January 16, 2019, President Trump...more
On January 29 and 30, 2019, the Internal Revenue Service’s Large Business and International (LB&I) division released new Practice Units on Permanent Establishments. Permanent Establishments create taxing nexus for foreign...more
Clients ask us all of the time, “What is the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS)?” Recently, the JCT has released an overview of its process....more
Tax reform made many structural changes to our tax system. Changes to Code Section 274, however, sent shudders through corporate America. As amended, Code Section 274 eliminated the 50 percent deduction for “entertainment”...more
A battery storage system added to a pre-existing wind facility is eligible for the investment tax credit, even if the facility has claimed the production tax credit. This is good news for taxpayers considering adding...more
Changes to the energy credits proposed in the Tax Cuts and Jobs Act could impact the eligibility of renewable energy projects that had been relying on the guidance previously issued by the Internal Revenue Service....more
Taxpayers’ section 199 computer software deductions are under attack! The issue is being coordinated within the IRS, and at Exam and Appeals taxpayers are running into a brick wall. A resource-starved IRS is trying to treat...more
In a highly-anticipated Technical Advice Memorandum (TAM) dated March 23, 2017 and released on July 21, 2017, the Internal Revenue Service (IRS) ruled that two taxpayers who had invested in a Limited Liability Company that...more
On March 20, 2017, the Internal Revenue Service (IRS) issued Revenue Procedure 2017-28, which provides guidance to employers on obtaining employee consents used to support a claim for credit or refund of overpaid taxes under...more
On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been...more
On May 18, 2016, the Internal Revenue Service (IRS) revised Notice 2016-31 (Notice), its recent guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass,...more
On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, providing guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal,...more
With the recent extension of the federal income tax credits available for renewable energy projects, practitioners and industry participants have raised questions as to how the “begun construction” rules will apply under...more
On November 2, 2015, President Barack Obama signed the Bipartisan Budget Act of 2015 (the Act) into law, instituting for tax years commencing after 2017 significant changes to the rules governing federal tax audits of...more
On May 26, 2015, the Tax Court issued its opinion in Pacific Management Group v. Commissioner, T.C. Memo. 2015-97, holding that a privilege log provided to the Internal Revenue Service (IRS) was inadequate to sustain claims...more
The Internal Revenue Service (IRS) has drafted new rules relating to the filing of informal refund claims during an examination. An informal refund claim is a request for a refund by the taxpayer either in a written form,...more
In This Issue:
- Waiver of Privilege: Disturbing Trends
- New Repair Regulations Affect All Taxpayers
- Unclaimed Property – It Is Not a Tax, but It Can Feel Like One
- Excerpt from Waiver of...more
Most of us are aware of the timely-mailed-timely-filed “mailbox rule” contained within the Internal Revenue Code. Most of us are probably also aware that a document mailed with a private delivery service may also qualify for...more
In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more