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Notice

Comments sought on issues relating to implementation of new partnership audit rules

Comments sought on issues relating to implementation of new partnership audit rules

Notice 2016-23, 2016-12 IRB In a Notice, IRS is seeking comments on the new partnership audit regime, enacted as part of the Bipartisan Budget Act of 2015 (P.L. 114-74, the BBA). The new audit regime is generally effective for tax years beginning after 2017, but parts of it can apply at the partnership’s election to […]

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Housing cost allowances issued for those working abroad in high-cost areas in 2016

Housing cost allowances issued for those working abroad in high-cost areas in 2016

Notice 2016-21, 2016-12 IRB A new Notice provides adjustments to the limitation on housing expenses under the Code Sec. 911 housing cost exclusion for specific locations for 2016. The Notice further provides that some taxpayers may elect to apply the 2016 limitation for tax years beginning in 2015. Background. A qualified individual may elect to […]

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ACA excise tax transition relief for student health coverage arrangements

ACA excise tax transition relief for student health coverage arrangements

Notice 2016-17, 2016-9 IRB In a Notice, IRS has provided a transition period for the application of certain market reforms to certain arrangements offered by institutions of higher education to their students, that are designed to reduce the cost of student health coverage. This relief apples for plan years beginning before Jan. 1, 2017. Background. The […]

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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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Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice 2016-10, 2016-6 IRB In a Notice, IRS has provided guidance with regard to regs it intends to issue on alternative methods that regulated investment companies (RICs) and their shareholders may use to satisfy their obligations under Code Sec. 853 and Code Sec. 905(c) where a RIC receives a refund of a foreign tax that […]

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Procedure for employers to deal with retroactive increase in excludible 2015 transit benefits

Procedure for employers to deal with retroactive increase in excludible 2015 transit benefits

Notice 2016-6, 2016-4 IRB In a Notice, IRS has provided guidance on how employers should handle the retroactive 2015 increase, by the Consolidated Appropriations Act, 2016 (the Act, P.L. 114-113), in the monthly exclusion for employer-provided transit and vanpooling benefits under Code Sec. 132(f)(2)(A), from $130 to $250. IRS clarifies how the increase applies for […]

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IRS provides procedures for claims related to retroactively extended fuel credits

IRS provides procedures for claims related to retroactively extended fuel credits

Notice 2016-5, 2016-6 IRB To take into effect the retroactive extension of certain fuel tax credits under the Protecting Americans from Tax Hikes (PATH) Act, IRS has issued a Notice that provides rules that taxpayers must follow to make a one-time claim for a refund of, or credit for, certain fuels sold or used during […]

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IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

Notice 2016-8, 2016-6 IRB In a Notice, IRS has announced that it intends to amend several regs with respect to chapters 3 (withholding of tax on nonresident aliens and foreign corporations) and 4 (the Foreign Account Tax Compliance Act; FATCA) of the Code to reduce a number of compliance burdens. Prior to the issuance of […]

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Notice clarifies requirements for tax-exempt bond financing for State Supplemental Loan programs

Notice clarifies requirements for tax-exempt bond financing for State Supplemental Loan programs

Notice 2015-78, IRB 2015-48 In a Notice, IRS has provided guidance on qualified student loan bonds under Code Sec. 144(b) to clarify certain requirements for tax-exempt bond financing for State Supplemental Loan programs. Background. Under Code Sec. 144(b)(1), a qualified student loan bond for which tax-exempt private activity bonds may be issued means any bond […]

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IRS extends safe harbor for governmental homeowner assistance payments through 2017

IRS extends safe harbor for governmental homeowner assistance payments through 2017

Notice 2015-77, 2015-47 IRB In a Notice, IRS has extended through 2017 earlier guidance on the tax consequences of programs that involve payments made to or on behalf of financially distressed homeowners; the guidance includes a safe harbor method for computing a homeowner’s deduction for payments made on a home mortgage. The Notice also extends […]

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IRS changes date used in identifying transactions same as or similar to basket transactions

IRS changes date used in identifying transactions same as or similar to basket transactions

Notice 2015-73, 2015-46 IRB; Notice 2015-74, 2015-46 IRB IRS has amended and re-issued two recently released Notices on “basket option contracts” and “basket contracts” — two types of structured financial transactions that IRS has respectively determined are, or have the potential to be used as, tax avoidance transactions. Both Notices stated that, to be considered […]

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IRS will update its procedures for administrative appeals of docketed cases

IRS will update its procedures for administrative appeals of docketed cases

Notice 2015-72, 2015-44 IRB In a Notice, IRS has provided a proposed revenue procedure which will update its published description of the IRS administrative appeals process in cases docketed in the Tax Court. Background. Prop Reg § 601.106(c)(3) and Rev Proc 87-24, 1987-1 CB 720, describe IRS’s administrative appeals process in cases docketed in the Tax […]

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IRS releases adjusted dollar amount for Patient-Centered Outcomes Research Institute fee

IRS releases adjusted dollar amount for Patient-Centered Outcomes Research Institute fee

Notice 2015-60, 2015-43 IRB In a Notice, IRS has provided the adjusted applicable dollar amount to be multiplied by the average number of covered lives for purposes of the Patient-Centered Outcomes Research Institute fee imposed by Code Sec. 4375 and Code Sec. 4376 for policy and plan years that end on or after Oct. 1, […]

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IRS offers preview of proposed regs on health insurance coverage reporting

IRS offers preview of proposed regs on health insurance coverage reporting

Notice 2015-68, 2015-41 IRB In a Notice, IRS has advised taxpayers of its intent to issue proposed regs under Code Sec. 6055 that would, among other things, clarify reporting requirements with respect to catastrophic health insurance plans enrolled in through an Exchange and modify the existing “supplemental coverage rule.” The Notice also provides penalty relief […]

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Application of jeopardizing investment excise tax to non-program-related investments

Application of jeopardizing investment excise tax to non-program-related investments

Notice 2015-62, 2015-39 IRB In a Notice, IRS has provided guidance on the application of the excise tax under Code Sec. 4944 to investments that are made by private foundations for charitable purposes described in Code Sec. 170(c)(2)(B), but do not meet the other requirements to qualify as program-related investments (PRIs) excepted from treatment as […]

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IRS describes areas of concern under Code Sec. 355 & expands no-rule areas

IRS describes areas of concern under Code Sec. 355 & expands no-rule areas

Notice 2015-59, 2015-40 IRB, Rev Proc 2015-43, 2015-40 IRB In a Notice, IRS has announced that it is studying issues under Code Sec. 355 (and Code Sec. 337(d)) relating to certain distributions, described in Code Sec. 355, in which property becomes the property of a regulated investment company (RIC) or a real estate investment trust […]

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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 Notice describes areas of concern under Code Sec. 355

IRS Notice describes areas of concern under Code Sec. 355

Notice 2015-59, 2015-40 IRB, Rev Proc 2015-43, 2015-40 IRB In a Notice, IRS has announced that it is studying issues under Code Sec. 355 (and Code Sec. 337(d)) relating to certain distributions, described in Code Sec. 355, in which property becomes the property of a regulated investment company (RIC) or a real estate investment trust […]

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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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Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Notice 2015-54, 2015-34 IRB In a Notice, IRS has announced that it intends to issue regs under Code Sec. 721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the […]

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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