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Interest

Applicable Federal Rates for May

Applicable Federal Rates for May

Rev Rul 2016-11, 2016-19 IRB The Applicable Federal Rates for May 2016 are reproduced below. Table 1 Applicable Federal Rates (AFRs) for May 2016 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .67% .67% .67% .67% 110% AFR .74% .74% .74% .74% 120% AFR .80% .80% .80% .80% 130% AFR .87% .87% .87% .87% […]

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Applicable Federal Rates for April

Applicable Federal Rates for April

Rev Rul 2016-9, 2016-14 IRB The Applicable Federal Rates for April 2016 are reproduced below. Table 1 Applicable Federal Rates (AFRs) for April 2016 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .70% .70% .70% .70% 110% AFR .77% .77% .77% .77% 120% AFR .84% .84% .84% .84% 130% AFR .91% .91% .91% .91% […]

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IRS correction; overpayment and underpayment rates increase 1% for second quarter, 2016

IRS correction; overpayment and underpayment rates increase 1% for second quarter, 2016

Rev Rul 2016-6, 2016-13 IRB; IR 2016-41 IRS has announced that the interest rates for tax overpayments and underpayments will increase by one percentage point for the second quarter of 2016. Note: Earlier this week, IRS issued versions of the above Revenue Ruling and Information Release that provided that rates had not changed for the second […]

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Overpayment and underpayment rates remain the same for the second quarter, 2016

Overpayment and underpayment rates remain the same for the second quarter, 2016

Rev Rul 2016-6, 2016-13 IRB; IR 2016-25 IRS has announced that the interest rates for tax overpayments and underpayments for the calendar quarter beginning Apr. 1, 2016 will remain the same as for the first quarter of 2016. Note: The interest rates for tax overpayments and underpayments have remained constant for nineteen quarters in a row (i.e., beginning […]

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Applicable Federal Rates for March

Applicable Federal Rates for March

Rev Rul 2016-7, 2016-10 IRB The Applicable Federal Rates for March 2016 are reproduced below. Table 1 Applicable Federal Rates (AFR) for March 2016 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .65% .65% .65% .65% 110% AFR .72% .72% .72% .72% 120% AFR .78% .78% .78% .78% 130% AFR .85% .85% .85% .85% […]

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Applicable Federal Rates for February

Applicable Federal Rates for February

Rev Rul 2016-4, IRB 2016-6 The Applicable Federal Rates for February 2016 are reproduced below. Table 1 Applicable Federal Rates (AFR) for February 2016 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .81% .81% .81% .81% 110% AFR .89% .89% .89% .89% 120% AFR .97% .97% .97% .97% 130% AFR 1.05% 1.05% 1.05% 1.05% […]

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Court of Appeals affirms; corporate overpayment interest rate applies to nonprofit corporations

Court of Appeals affirms; corporate overpayment interest rate applies to nonprofit corporations

Maimonides Medical Center, (CA 2 12/18/2015) 116 AFTR 2d ¶ 2015-5531 The Court of Appeals for the Second Circuit, affirming a district court opinion, has held that the interest rate that IRS is required to pay with respect to tax overpayments by corporations, which is a lower rate than that which applies to overpayments by […]

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Percentage-of-completion method look-back interest isn’t eligible for netting

Percentage-of-completion method look-back interest isn’t eligible for netting

Program Manager Technical Advice 2015-016 In Program Manager Technical Advice, IRS has concluded that look-back interest that either the taxpayer owes IRS or IRS owes the taxpayer, at the conclusion of a contract accounted for under the percentage-of-completion method (PCM), is not eligible for interest netting, but that any underpayment/overpayment interest arising from look-back interest […]

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Applicable Federal Rates for January

Applicable Federal Rates for January

Rev Rul 2016-1, 2016-2 IRB The Applicable Federal Rates for January 2016 are reproduced below. Table 1 Applicable Federal Rates (AFR) for January 2016 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .75% .75% .75% .75% 110% AFR .83% .83% .83% .83% 120% AFR .90% .90% .90% .90% 130% AFR .98% .98% .98% .98% […]

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Applicable Federal Rates for December

Applicable Federal Rates for December

Rev Rul 2015-25, 2015-49 IRB The Applicable Federal Rates for December 2015 are reproduced below. Table 1 Applicable Federal Rates (AFR) for December 2015 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .56% .56% .56% .56% 110% AFR .62% .62% .62% .62% 120% AFR .67% .67% .67% .67% 130% AFR .73% .73% .73% .73% […]

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Applicable Federal Rates for November

Applicable Federal Rates for November

Rev Rul 2015-22, 2015-44 IRB The Applicable Federal Rates for November 2015 are reproduced below.   Table 1 Applicable Federal Rates (AFR) for November 2015 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .49% .49% .49% .49% 110% AFR .54% .54% .54% .54% 120% AFR .59% .59% .59% .59% 130% AFR .64% .64% .64% […]

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Applicable federal rates for October

Applicable federal rates for October

  Rev Rul 2015-21, 2015-40 IRB The Applicable Federal Rates for October 2015 are reproduced below. Table 1 Applicable Federal Rates (AFR) for October 2015 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .55% .55% .55% .55% 110% AFR .61% .61% .61% .61% 120% AFR .66% .66% .66% .66% 130% AFR .72% .72% .72% […]

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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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Court of Federal Claims holds that S corporations are subject to same lower interest rates on tax overpayments as C corporations

Court of Federal Claims holds that S corporations are subject to same lower interest rates on tax overpayments as C corporations

Eaglehawk Carbon, Inc. v. U.S., (Ct Fed Cl 7/16/2015) 116 AFTR 2d ¶2015-5053 The Court of Federal Claims has held that the corporate overpayment interest rates of Code Sec. 6621(a)(1) apply to S corporations, rejecting a taxpayer’s claim that it was owed additional interest on tax overpayments that it made over a 5-year period. The […]

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Proposed regs would revise method of computing adjusted Federal rates

Proposed regs would revise method of computing adjusted Federal rates

Preamble to Prop Reg 02/27/2015, Prop Reg § 1.382-12, Prop Reg § 1.1288-1 IRS has issued Proposed Regs that would change the method used to adjust the applicable Federal rates (AFRs) under Code Sec. 1288 (adjusted AFRs) for tax-exempt obligations and the method to be used to determine the long-term tax-exempt rate and the adjusted […]

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Applicable Federal Rates for August

Applicable Federal Rates for August

Rev Rul 2015-16, 2015-31 IRB The Applicable Federal Rates for August 2015 are reproduced below.   Table 1 Applicable Federal Rates (AFR) for August 2015 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .48% .48% .48% .48% 110% AFR .53% .53% .53% .53% 120% AFR .58% .58% .58% .58% 130% AFR .62% .62% .62% […]

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Supreme Court Won’t Hear Case Denying Taxpayer Interest on Cash Bond Remittances

Supreme Court Won’t Hear Case Denying Taxpayer Interest on Cash Bond Remittances

Ford Motor Co. v. U.S., (CA 6, 2014) 114 AFTR 2d 2014-6173, cert denied 6/22/2015 The Supreme Court has refused to hear a case in which the Court of Appeals for the Sixth Circuit, affirming the district court, denied $445 million in overpayment interest on remittances made as cash bonds, until after the Ford Motor […]

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Applicable federal rates for July

Applicable federal rates for July

Rev Rul 2015-14, 2015-22 IRB The Applicable Federal Rates for July 2015 are reproduced below. Table 1 Applicable Federal Rates (AFR) for July 2015 Period for Compounding Annual Semiannual Quarterly Monthly Short-Term AFR .48% .48% .48% .48% 110% AFR .53% .53% .53% .53% 120% AFR .58% .58% .58% .58% 130% AFR .62% .62% .62% .62% […]

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Court of Appeals denies STARS transaction foreign tax credits, allows interest deductions

Court of Appeals denies STARS transaction foreign tax credits, allows interest deductions

Salem Financial Inc., (CA FC 5/14/2015) 115 AFTR 2d ¶ 2015-743 The Court of Appeals for the Federal Circuit has ruled that the portion of a”structured trust advantaged repackaged securities” (STARS) transaction involving the use of a trust to generate foreign tax credits (FTCs) had no economic substance, but that the portion in which the […]

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Overpayment and underpayment rates remain the same for third quarter, 2015

Overpayment and underpayment rates remain the same for third quarter, 2015

Rev Rul 2015-12, 2015-26 IRB; IR 2015-8449 IRS has announced that the interest rates for tax overpayments and underpayments for the calendar quarter beginning July 1, 2015 will remain the same as for the second quarter of 2015. Note: The interest rates for tax overpayments and underpayments have remained constant for sixteen quarters in 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