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Announcements

New IRS report provides details on 2015 advance pricing agreements

New IRS report provides details on 2015 advance pricing agreements

Ann. 2016-12, 2016-16 IRB In an Announcement, IRS has released its seventeenth required report providing details on the experience, structure, and activities of the Advance Pricing and Mutual Agreement (APMA) Program. The number of new advance pricing agreements (APAs) executed decreased from 53 in 2014 to 44 in 2015, while the total number of all […]

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IRS provides new accounting method change form and transition period from old form

IRS provides new accounting method change form and transition period from old form

Ann. 2016-14 Form 3115, Application for Change in Accounting Method (Rev. December 2015) Instructions for Form 3115, Application for Change in Accounting Method (Rev. December 2015)) IRS has issued a revised Form 3115, Application for Change in Accounting Method, instructions to that form, and an announcement about the form that provides for a transition from […]

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New IRS initiative aims for earlier detection of potential payroll issues

New IRS initiative aims for earlier detection of potential payroll issues

In a recent e-News for Payroll Professionals, IRS’s Collection Division (Collection) announced a new program called “Early Interaction Initiative” (the Initiative). The Initiative is designed to help employers meet their payroll tax responsibilities and resolve issues before they become major problems for the business.  Click here to view “IRS Collection Launches Early Interaction Initiative”. Background. Payroll […]

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Identity protection services provided to individuals affected by data breach aren’t taxable

Identity protection services provided to individuals affected by data breach aren’t taxable

Ann. 2015-22, 2015-35 IRB IRS has announced that when an individual receives identity protection services from an organization at no cost following a data security breach, the individual isn’t required to include the value of those services in gross income, and the organization isn’t required to report these amounts on information returns filed with respect […]

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Employee plan determination letter program to be revised; no off-cycle letter applications

Employee plan determination letter program to be revised; no off-cycle letter applications

Ann. 2015-19, 2015-32 IRB IRS has announced that, effective Jan. 1, 2017, the staggered 5-year determination letter remedial amendment cycles for individually designed plans will be eliminated, and the scope of the determination letter program for individually designed plans will be limited to initial plan qualification and qualification upon plan termination. A transition rule will […]

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IRS Announcement – based on S. Ct Decision that severance pay is subject to FICA, IRS will deny refund claims

IRS Announcement – based on S. Ct Decision that severance pay is subject to FICA, IRS will deny refund claims

Ann. 2015-8, 2015-9 IRB In an Announcement, IRS has provided guidance on the application of the Supreme Court’s Quality Stores decision to claims for refund of employment taxes. In that decision the Supreme Court held that severance payments were wages subject to Federal Insurance Contributions Act (FICA) tax. IRS will disallow all claims for refund of FICA […]

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IRS reminds retirement plans of July 31 return due date and unfiled return penalty relief

IRS reminds retirement plans of July 31 return due date and unfiled return penalty relief

IR 2015-96 In a News Release, IRS has issued a reminder that: a) for calendar year retirement plans, a return in the 5500 series is, in most cases, due on July 31; and b) IRS offers penalty relief for retirement plans that have failed to file previously due 5500 series returns. Background—return due date. A funded […]

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IRS will only issue estate tax closing letters on request

IRS will only issue estate tax closing letters on request

IRS has announced that, for estate tax returns filed on or after June 1, 2015, estate tax closing letters will be issued only upon request by the taxpayer. It has also clarified whether it will, under various circumstances, issue a closing letter with respect to estate tax returns filed before June 1, 2015. Click here […]

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New IRS report provides details on 2014 advance pricing agreements

New IRS report provides details on 2014 advance pricing agreements

Ann. 2015-11, 2015-15 IRB   In an Announcement, IRS has released its sixteenth required report providing details on the experience, structure, and activities of the Advance Pricing and Mutual Agreement (APMA) Program. During 2014, the number of new APAs increased from 45 in 2013 to 52 in 2014, while the total number of all APAs […]

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IRS Provides Relief to Bondholders When Tax-Exempt Organization Loses Exempt Status

IRS Provides Relief to Bondholders When Tax-Exempt Organization Loses Exempt Status

Ann. 2015-02, 2015-03 IRB In an Announcement, IRS has provided a simplified process for issuers of qualified Code Sec. 501(c)(3) bonds to request a closing agreement in situations in which the borrower of the proceeds of the bonds had its exempt status revoked and then had it reinstated but not retroactively. If the steps of […]

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2015 Changes To IRS’s Employee Plans Determination Letter Program

2015 Changes To IRS’s Employee Plans Determination Letter Program

Ann. 2015-1, 2015-2 IRB   IRS has announced several changes to the Employee Plans determination letter program that will take effect in 2015 and that are being adopted as a result of a process improvement strategy designed to promote case processing efficiency. These changes will be reflected in Rev Proc 2015-6, 2015-IRB, which is updated […]

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Business Standard Mileage Rate Increases For 2015; Other Mileage Rates Decrease Slightly

Business Standard Mileage Rate Increases For 2015; Other Mileage Rates Decrease Slightly

Notice 2014-79, 2014-52 IRB; IR 2014-114 IRS has announced that the optional mileage allowance for owned or leased autos (including vans, pickups or panel trucks) will increase by 1.5¢ to 57.5¢ per mile for business travel after 2014. This rate can also be used by employers to provide tax-free reimbursements to employees who supply their […]

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IRS explains effect of TE/GE realignment on issuance of certain rulings and published guidance

IRS explains effect of TE/GE realignment on issuance of certain rulings and published guidance

Ann. 2014-34, 2014-51 IRB In an Announcement, IRS has previewed the transfer from the Tax Exempt and Government Entities Division (TE/GE) of certain technical responsibility for issues involving exempt organizations, qualified retirement plans, and individual retirement annuities and accounts (collectively, IRAs) that will occur as part of the realignment of TE/GE at the beginning of […]

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IRS Extends Deadline To Submit Letter Applications For Certain Defined Benefit Plans

IRS Extends Deadline To Submit Letter Applications For Certain Defined Benefit Plans

Ann. 2014-41, 2014-52 IRB IRS has announced that the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans, for the plans’ second 6-year remedial amendment cycle, has been extended from Feb. 2, 2015, to June 30, 2015. This extension applies to defined benefit mass submitter lead and specimen plans, […]

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Deadline extended for FATCA IGAs that are not yet signed but are treated as in effect

Deadline extended for FATCA IGAs that are not yet signed but are treated as in effect

Ann. 2014-38, 2014-51 IRB In an Announcement, IRS has provided that a jurisdiction that is treated as if it had an intergovernmental agreement (IGA) in effect to implement the Foreign Account Tax Compliance Act (FATCA) provisions, but that has not yet signed an IGA, will retain that status beyond Dec. 31, 2014, if the jurisdiction […]

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Employers in 7 states and the Virgin Islands will face higher FUTA rates for 2014

Employers in 7 states and the Virgin Islands will face higher FUTA rates for 2014

The U.S. Department of Labor (DOL) has released a schedule that shows the states that, because they have had an outstanding federal unemployment insurance (UI) loan for at least two years, are subject to federal unemployment tax (FUTA) credit reduction on 2014 federal Form 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return. Click here for […]

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IRS provides guidance for applying the one-IRA-rollover-per-year rule

IRS provides guidance for applying the one-IRA-rollover-per-year rule

Ann. 2014-32, 2014-48 IRB; IR 2014-107 In an Announcement and an accompanying News Release, IRS has issued several additional rules to flesh out the application of the one-IRA-rollover-per-year rule that it announced earlier this year would go into effect on Jan. 1, 2015. One such rule is a transition rule for distributions made in 2015. […]

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IRS policy change: aliens may keep ITINs indefinitely if they use them on tax returns

IRS policy change: aliens may keep ITINs indefinitely if they use them on tax returns

IR 2014-76 IRS has announced that it is changing its policy under which Individual Taxpayer Identification Numbers (ITINs) issued to aliens, which formerly were to expire automatically after five years, will only expire if not used on a federal income tax return for five consecutive years. Background. ITINs, upon application, are issued by IRS to […]

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IRS extends deadline to submit letter applications for certain defined benefit plans

IRS extends deadline to submit letter applications for certain defined benefit plans

In Announcement  2014-4, 2014-7 IRB, IRS has announced that the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans, for the plans’ second six-year remedial amendment cycle, has been extended from Jan. 31, 2014 to Feb. 2, 2015. This extension applies to defined benefit mass submitter lead and specimen […]

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IRS announces reduction in certain services & shift to automatic resources

IRS announces reduction in certain services & shift to automatic resources

On its website, IRS has announced that it will be making a number of taxpayer service changes for the 2014 filing season to reflect “available resources and shifting taxpayer demands.” In general, these changes reflect a cutback of live assistance in favor of more automated options. Click here for IRS’s announcement, “Some IRS Assistance and […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney