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Program Manager Technical Advice (PMTA)

IRS: Cash reimbursements to reflect retroactive transit benefit increase may be taxable

IRS: Cash reimbursements to reflect retroactive transit benefit increase may be taxable

Program Manager Technical Advice 2016-001 In Program Manager Technical Advice (PMTA), IRS has concluded that: a) where transit passes are readily available, cash payments from employers to employees, to reflect retroactive legislation that increased the amount of the exemption for qualified transportation fringe benefits, are taxable compensation; and b) an employee’s maximum excludible qualified transportation […]

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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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“Returns” filed by identity thieves are invalid; IRS may disclose information to victims

“Returns” filed by identity thieves are invalid; IRS may disclose information to victims

  Program Manager Technical Advice 2015-019 In Program Manager Technical Advice, IRS has concluded that purported returns filed in two different identity theft scenarios weren’t returns under the Code, that information on the purported returns was nonetheless return information, and that IRS could disclose that return information to the identity theft victim for purposes of […]

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IRS to use abatement, not IRS-prepared return, to extinguish assessment on PEO

IRS to use abatement, not IRS-prepared return, to extinguish assessment on PEO

Program Manager Technical Advice 2015-010 In Program Manager Technical Advice, IRS has concluded that the Code Sec. 6404 abatement rules, and not the Code Sec. 6020(b) rules (which authorize IRS to prepare substitute returns for non-filers), provide the legal authority for IRS to extinguish employment tax liabilities assessed against a professional employer organization (PEO) that […]

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IRS explains how to apply accuracy related penalty to undisclosed listed transaction

IRS explains how to apply accuracy related penalty to undisclosed listed transaction

Program Manager Technical Advice 2015-11 Click here for Program Managers Technical Advice 2015-11. In legal advice issued to program managers (PMTA), IRS has explained how to apply the 30% accuracy-related penalty under Code Sec. 6662A(c), to taxpayers who didn’t disclose participation in a listed transaction that used cash value life insurance policies to provide welfare […]

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IRS has authority to limit e-filing access where stolen identity is used

IRS has authority to limit e-filing access where stolen identity is used

Program Manager Technical Advice 2014-08   In a Program Manager Technical Advice (PMTA), IRS has concluded that it has the authority to adopt rules that deny an application to become an IRS e-file Provider or expel an individual from participation in the IRS e-file, when a stolen identity is used to apply for an electronic […]

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IRS explains application and procedural aspects of erroneous refund claim penalty

IRS explains application and procedural aspects of erroneous refund claim penalty

Program Manager Technical Advice 2014-015 In Program Manager Technical Advice (PMTA), IRS has explained various aspects of the Code Sec. 6676 erroneous refund/credit claim penalty, including when, as a practical matter, it does and doesn’t apply and whether it is subject to deficiency procedures. Background. If a claim for refund or credit of income tax […]

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IRS changes guidance on low-income housing credit housing commitment rule

IRS changes guidance on low-income housing credit housing commitment rule

Program Manager Technical Advice 2015-003   In Program Manager Technical Advice, IRS has recommended: a) the withdrawal of a 2007 internal memorandum that gave its auditors specific instructions regarding the application of the “extended low-income housing commitment” rule under the low-income housing credit to a specific type of situation; and b) allowing the auditors more […]

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IRS advice on application of air transportation tax to certain prepaid cards

IRS advice on application of air transportation tax to certain prepaid cards

Program Manager Technical Advice 2015-001   In Program Manager Technical Advice (PMTA), IRS has provided guidance on whether amounts paid for two types of prepaid cards that can be used to pay for air transportation are subject to the Code Sec. 4261 air transportation tax. Background. Code Sec. 4261(a) imposes a tax on the amount […]

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IRS provides guidance on last known address of prisoners

IRS provides guidance on last known address of prisoners

Program Manager Technical Advice 2014-19   In Program Manager Technical Advice, IRS has provided guidance on determining what the last known address is of a taxpayer who is a prisoner, including what that address is where IRS has specific knowledge of the taxpayer’s incarceration. Background. The term “last known address” is defined in Reg. § 301.6212-2(a) […]

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Executor’s failure to report foreign financial assets triggered suspended assessment period

Executor’s failure to report foreign financial assets triggered suspended assessment period

Program Manager Technical Advice 2014-018 In a Program Manager Technical Advice (PMTA), IRS has concluded that Code Sec. 6501(c)(8) will operate to extend the period of limitations for the assessment of tax with respect to an estate’s Form 1041 (U.S. Income Tax Return for Estates and Trusts) and Form 706 (United States Estate (and Generation-Skipping […]

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IRS provides advice on various S corporation and partnership late filing scenarios

IRS provides advice on various S corporation and partnership late filing scenarios

In Program Manager Technical Advice (PMTA), 2013-015, IRS has created a series of scenarios in which S corporation and/or partnership returns are not filed on time and explained the penalty ramifications of those scenarios. Background. Code Sec. 6651(a)(1) provides for a penalty in the event a taxpayer fails to file a timely return unless the […]

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IRS Clarifies Its Position On Estate Tax Levies That Are Based On “Like Liens” On Transferees

IRS Clarifies Its Position On Estate Tax Levies That Are Based On “Like Liens” On Transferees

In Program Manager Technical Assistance (PMTA), 2013-014,  IRS has concluded that a Collection Due Process (CDP) notice need not be provided to a party that received estate property when IRS levies based upon the “like lien” that arises under Code Sec. 6324(a)(2) upon transfer of that property by that party to a purchaser or security […]

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IRS provides non-safe-harbor guidance for Ponzi scheme victims

IRS provides non-safe-harbor guidance for Ponzi scheme victims

In Program Manager Technical Advice 2013-003, IRS has provided guidance to persons who have “phantom income” from a fraudulent investment scheme and who do not or cannot use the safe harbor procedures provided in Rev Proc 2009-20, 2009-14 IRB 749. Click here for the text of Program Manager Technical Assistance 2013-003. Program Manager Technical Advice. […]

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Longer interest disallowance period applies to some Form 1042 overpayments

Longer interest disallowance period applies to some Form 1042 overpayments

In Program Manager Technical Advice (PMTA) 2013-001, IRS has examined when the Code Sec. 6611(e)(4) 180-day interest disallowance period applies to overpayments reported on a Form 1042. IRS says that it applies to the extent the overpayment results from tax withheld under Code Sec. 1441 through Code Sec. 1446 or tax paid under Code Sec. […]

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IRS guidance on assessment period for penalty for failing to file W-2s and 1099s

IRS guidance on assessment period for penalty for failing to file W-2s and 1099s

In Program Manager Technical Advice 2013-04, the IRS has provided guidance as to the running of the assessment period for penalties for failing to file Forms W-2 and/or 1099 with IRS and for failing to provide a copy of those forms to the payee. Program Manager Technical Advice. These documents are legal advice, signed by […]

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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