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Guidance

New guidance explains IRS’s procedures for administrative appeals of docketed cases

New guidance explains IRS’s procedures for administrative appeals of docketed cases

Rev Proc 2016-22, 2016-15 IRB IRS has issued a Revenue Procedure to update its description of the administrative appeals process in cases docketed in the Tax Court. Background. Rev Proc 87-24, 1987-1 CB 720 describes IRS’s administrative appeals process in cases docketed in the Tax Court. The Office of Chief Counsel (Counsel) is charged with the […]

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New guidance sheds light on arm’s length standard for interest on inbound intercompany loans

New guidance sheds light on arm’s length standard for interest on inbound intercompany loans

LB&I International Practice Service Transaction Unit, “Intercompany Interest Rates under the Situs Rule of IRC Section 482.” In a new International Practice Unit (IPU), IRS provides guidance to its examiners on whether the interest rate on a loan or advance from a foreign parent corporation (FPC) to a U.S. subsidiary (USS) (i.e., an inbound intercompany […]

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New guidance on permissible mid-year changes involving safe harbor plans

New guidance on permissible mid-year changes involving safe harbor plans

Notice 2016-16, 2016-7 IRB In a Notice, IRS has provided guidance on mid-year changes to a safe harbor plan under Code Sec. 401(k) and Code Sec. 401(m). A mid-year change either to a safe harbor plan or to a plan’s safe harbor notice won’t violate the safe harbor rules merely because it is a mid-year […]

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IRS issues guidance on health insurer fee and expatriate plans for 2016

IRS issues guidance on health insurer fee and expatriate plans for 2016

Notice 2016-14, 2016-7 IRB In a Notice, IRS has provided guidance for the 2016 fee year on how the definition of expatriate health plans under the Expatriate Health Coverage Clarification Act of 2014 applies for purposes of the health insurance provider’s fee imposed by Sec. 9010 of the Affordable Care Act. Background. Effective for calendar years […]

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Internal IRS guidance explains international information exchange programs

Internal IRS guidance explains international information exchange programs

IRS has released three new International Practice Units (IPUs) providing guidance to its examiners on exchange of information (EOI) programs. “EOI” refers to the sharing of tax-related information between two or more countries for tax administration and enforcement purposes, generally under the provisions of U.S. income tax treaties and other international tax information sharing agreements. […]

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IRS proposes drastic increase to enrolled agent examination fee

IRS proposes drastic increase to enrolled agent examination fee

Preamble to Prop Reg01/25/2016, Prop Reg § 300.4 Proposed regs on Special Enrollment Examination User Fee for Enrolled Agents. IRS has issued proposed regs that would raise the fee for taking the 3-part enrolled agent special enrollment examination from $11 to $99 per part (i.e., $297 for all three parts). This amount doesn’t include any […]

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IRS provides guidance on revised Employee Plans determination letter program

IRS provides guidance on revised Employee Plans determination letter program

Notice 2016-3, 2016-3 IRB In anticipation of the elimination of the 5-year remedial amendment cycle system for individually designed plans under the Employee Plans determination letter program, effective Jan. 1, 2017, IRS has announced guidance with respect to Cycle A elections made by controlled groups and affiliated service groups; expiration dates on determination letters issued prior […]

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IRS to apply Code’s church audit restrictions to church employment tax inquiries, audits

IRS to apply Code’s church audit restrictions to church employment tax inquiries, audits

RS Small Business/Self Employed Division Memo “IRC section 7611 Procedures Relating to Employment Tax Examinations of Churches (Dec. 17, 2015). In a memo, IRS’s Small Business/Self Employed (SB/SE) division has changed its instructions to its examiners, telling them to apply procedures in Code Sec. 7611, which restrict IRS inquiries and examinations involving churches’ tax-exempt status […]

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IRS issues FATCA updates and new guidance

IRS issues FATCA updates and new guidance

IRS has announced that it has released six new YouTube videos explaining upgrades to the Foreign Account Tax Compliance Act (FATCA) Online Registration System, upgraded the Foreign Financial Institution (FFI) List Search and Download Tool, and added new frequently asked questions (FAQs) about general FATCA compliance. It also announced the dates on which the International […]

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Rev Proc provides detailed guidance on depreciation changes under TIPA

Rev Proc provides detailed guidance on depreciation changes under TIPA

Rev Proc 2015-48, 2015-40 IRB In a Revenue Procedure, IRS has provided guidance on changes made by the Tax Increase Prevention TIPA of 2014 (TIPA, P.L. 113-295) to provisions dealing with Code Sec. 168(k) bonus depreciation, the Code Sec. 168(k)(4) election to forego bonus depreciation and increase the alternative minimum tax credit, and the Code […]

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IRS will amend FATCA regs to extend various transitional rules

Notice 2015-66, 2015-41 IRB In a Notice, IRS has announced that it will amend the Foreign Account Tax Compliance Act (FATCA) regs to extend the period of time that certain transitional rules will apply and to modify the rules for grandfathered obligations in relation to collateral held by withholding agents. The Notice also provides information […]

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IRS issues guidance to its examiners on auditing transactions under sections 367(b) and 482

IRS issues guidance to its examiners on auditing transactions under sections 367(b) and 482

IRS has released two international practice units (IPUs) providing an overview of foreign-to-foreign transactions under Code Sec. 367(b) and transfer pricing under Code Sec. 482. IPUs generally identify strategic areas of importance to IRS and can provide insights as to how IRS examiners may audit a particular issue or transaction. Background—foreign-to-foreign transactions under 367(b). With […]

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Guidance clarifies funding rules for Cooperative and Small Employer Charity (CSEC) plans

Guidance clarifies funding rules for Cooperative and Small Employer Charity (CSEC) plans

Notice 2015-58, 2015-37 IRB In a Notice, IRS has provided guidance on various issues on the application of the Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act, P.L. 113-97, 4/7/2014), which specifies minimum funding requirements and related rules for certain defined benefit pension plans maintained by groups of cooperatives and related entities and […]

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IRS addresses effect on interest netting where overpayment is later found invalid

IRS addresses effect on interest netting where overpayment is later found invalid

Program Manager Technical Advice 2015-009 In Program Manager Technical Advice, IRS has held that where taxpayer had a tax overpayment followed by a tax underpayment, and IRS initially allowed the two amounts to be netted for overpayment/underpayment interest purposes but later determined that there actually was no overpayment, the question of whether the taxpayer could […]

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IRS, issues, guidance, to its, examiners, on subpart, F, audits

IRS, issues, guidance, to its, examiners, on subpart, F, audits

IRS has released three new international practice units (IPUs) providing guidance to IRS agents on the audit of certain structures and transactions that may generate subpart F income. Noting that the subpart F and transfer pricing rules are “not mutually exclusive,” IRS directs its examiners to request the following additional resources: organizational charts, steps of […]

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Prop regs would establish test for when partnership allocation is disguised payment

Prop regs would establish test for when partnership allocation is disguised payment

Preamble to Prop Reg 07/22/2015; Prop Reg § 1.707-1, Prop Reg § 1.707-2, Prop Reg § 1.707-9, Prop Reg § 1.736-1 IRS has issued proposed regs that would provide guidance to partnerships and partners regarding when an arrangement will be treated as a disguised payment for services under Code Sec. 707(a)(2)(A). Notably, the proposed regs […]

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LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

A recently released memorandum to all employees at IRS’s Large Business and International (LB&I) Division provides guidance to IRS examiners on how to determine when a major component pertaining to steam or electric generation property has been replaced under Reg. § 1.263(a)-3(k). The memo generally provides that a major component is considered to be replaced, […]

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Interim guidance clarifies application of ACA & EHCCA to expatriate health plans

Interim guidance clarifies application of ACA & EHCCA to expatriate health plans

Notice 2015-43, 2015-29 IRB In a Notice, IRS has provided interim guidance on the application of certain provisions of the Affordable Care Act (ACA) to expatriate health insurance issuers, expatriate health plans, and employers in their capacity as plan sponsors of expatriate health plans, as defined in the Expatriate Health Coverage Clarification Act of 2014 […]

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Subsequent Stock Transfer To A Partnership Didn’t Defeat Tax-Free Treatment Under Code Sec. 351(A)

Subsequent Stock Transfer To A Partnership Didn’t Defeat Tax-Free Treatment Under Code Sec. 351(A)

PLR 201506008   IRS ruled privately that when stock is acquired in a Code Sec. 351(a) exchange and is subsequently transferred to a partnership as part of the same transaction, the subsequent transfer will not cause the first exchange to fail to qualify as a nontaxable transfer to a controlled corporation under Code Sec. 351(a). […]

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FASIT Didn’t Qualify Under Grandfather Rules

FASIT Didn’t Qualify Under Grandfather Rules

Legal Advice Issued by Field Attorneys 20150601F   In a highly redacted Legal Advice Issued by Field Attorneys (LAFA), IRS has concluded that an entity didn’t fall under the grandfather rules exempting it from the repeal of the financial asset securitization investment trust (FASIT) provisions. Further, payments with regards to stock didn’t qualify as a […]

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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