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Revenue Procedure

IRS issues 2016, and revised 2015, auto, light truck and van depreciation dollar limits

IRS issues 2016, and revised 2015, auto, light truck and van depreciation dollar limits

Rev Proc 2016-23, 2016-16 IRB IRS has released the inflation-adjusted Code Sec. 280F depreciation limits for business autos, light trucks and vans (including minivans) placed in service by the taxpayer in 2016, as well as the annual income inclusion amounts for such vehicles first leased in 2016. It has also released new and revised tables […]

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Final & temporary regs and Rev Proc modify low-income housing credit monitoring rules

Final & temporary regs and Rev Proc modify low-income housing credit monitoring rules

T.D. 9753, 02/23/2016; Reg. § 1.42-5; Reg. § 1.42-5T; Preamble to Prop Reg 02/23/2016; Prop Reg § 1.42-5; Rev Proc 2016-15, 2016-11 IRB TD 9753, Low-Income Housing Credit Compliance-Monitoring Regulations. PR 15034912, Notice of Proposed Rulemaking, Low-Income Housing Credit Compliance-Monitoring Regulations. IRS has issued final and temporary regs, the text of which also serves as […]

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IRS updates its procedures for administrative appeals of docketed cases

IRS updates its 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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IRS narrows requirement to file schedule m-3 to avoid penalties

IRS narrows requirement to file schedule m-3 to avoid penalties

Rev Proc 2016-13, 2016-4 IRB 290 IRS has issued a Revenue Procedure that contains IRS’s annual update of procedures that taxpayers must follow in order to meet the requirements for adequate disclosure that reduce the substantial understatement accuracy-related penalty and eliminate the preparer understatement penalty for unreasonable positions. The new Revenue Procedure eliminates the need […]

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IRS revokes prior ruling on “cascading” foreign reinsurance excise tax

IRS revokes prior ruling on “cascading” foreign reinsurance excise tax

Rev Proc 2016-3, 2016-3 IRB In light of a recent decision of the Court of Appeals for the District of Columbia Circuit, IRS has reconsidered and revoked Rev Rul 2008-15, 2008-1 CB 633, which involved application of the foreign reinsurance excise tax under Code Sec. 4371(e). Background. Code Sec. 4371 imposes a tax on premiums paid […]

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IRS provides 2015 inflation adjustments for civil penalties & corrects earlier issued 2016 figure

IRS provides 2015 inflation adjustments for civil penalties & corrects earlier issued 2016 figure

Rev Proc 2016-11, 2016-2 IRB In a Revenue Procedure, IRS has provided inflation-adjusted items for civil penalties under Code Sec. 6651, Code Sec. 6652(c), Code Sec. 6695, Code Sec. 6698, Code Sec. 6699, Code Sec. 6721, and Code Sec. 6722 for returns and statements required to be filed after Dec. 31, 2015. IRS also has […]

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Safe harbor for retail and restaurant businesses on when to deduct/capitalize remodeling costs

Safe harbor for retail and restaurant businesses on when to deduct/capitalize remodeling costs

Rev Proc 2015-56, 2015-49 IRB In a Revenue Procedure, IRS has provided a safe harbor method that taxpayers engaged in the trade or business of operating a retail establishment may use to determine whether costs paid or incurred to refresh or remodel a qualified building are deductible under Code Sec. 162(a), must be capitalized as […]

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Official inflation-adjusted tax rate schedule and other key tax figures for 2016

Official inflation-adjusted tax rate schedule and other key tax figures for 2016

Rev Proc 2015-53, 2015-44 IRB; IR 2015-119 IRS has issued official inflation-adjusted tax rate schedules and other key tax figures for 2016. Previously, RIA correctly calculated, among others, the following 2016 figures that are covered in the new revenue procedure and news release: Basic and additional standard deduction amounts Personal exemption amount Personal exemption phaseout […]

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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 adds 16 approved countries to list of countries with which it exchanges certain tax data

IRS adds 16 approved countries to list of countries with which it exchanges certain tax data

Rev Proc 2015-50, IRB 2015-42 In a Revenue Procedure, IRS has updated the list of countries with which Treasury and IRS have determined that it is appropriate to have an automatic exchange relationship under Reg. § 1.6049-8(a) and Reg. § 1.6049-4(b)(5), which require the reporting of certain deposit interest aggregating $10 or more paid to […]

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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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Rev Proc sets out when RICs that invest in other RICs satisfy 25% asset diversification test

Rev Proc sets out when RICs that invest in other RICs satisfy 25% asset diversification test

Rev Proc 2015-45, 2015-39 IRB In a Revenue Procedure issued contemporaneously with final regs on controlled groups and the regulated investment company (RIC) asset diversification test, IRS has described the conditions under which it will treat a RIC that invests in one or more other RICs as satisfying Code Sec. 851(b)(3)(B)’s 25% asset diversification requirements, […]

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New guidance issued on requesting competent authority assistance under tax treaties

New guidance issued on requesting competent authority assistance under tax treaties

Rev Proc 2015-40, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement (APMA) Program and the Treaty Assistance and Interpretation Team (TAIT) of the Deputy Commissioner (International), Large Business […]

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Economic performance safe harbor applies to contracts with services provided on regular basis

Economic performance safe harbor applies to contracts with services provided on regular basis

Rev Proc 2015-39, 2015-33 IRB In a Revenue Procedure, IRS has provided a safe harbor that allows accrual method recipients of services to treat economic performance as occurring ratably with respect to contracts under which the services are provided on a regular basis. Thus, under the safe harbor, a taxpayer can ratably expense the cost […]

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IRS provides procedures for requesting competent authority assistance under tax treaties

IRS provides procedures for requesting competent authority assistance under tax treaties

Rev Proc 2015-40, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement (APMA) Program and the Treaty Assistance and Interpretation Team (TAIT) of the Deputy Commissioner (International), Large Business […]

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IRS provides updated procedures for advance pricing agreements

IRS provides updated procedures for advance pricing agreements

Rev Proc 2015-41, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining advance pricing agreements (APAs) from the Advance Pricing and Mutual Agreement (APMA) program, a constituent office of the U.S. competent authority, within the office of the Deputy Commissioner International, Large Business & International Division. Guidance […]

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Revision to accounting method change Rev Proc provides liberal transition rule

Revision to accounting method change Rev Proc provides liberal transition rule

Rev Proc 2015-13, 2015-5 IRB 419   IRS has issued a revised version of Rev Proc 2015-13, which provides the general procedures under which taxpayers obtain IRS consent to change a method of accounting. The revised version provides taxpayers with a more liberal transition rule than was provided in the original version of Rev Proc […]

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IRS Eases Process For Small Businesses To Adopt Tangible Property Regs

IRS Eases Process For Small Businesses To Adopt Tangible Property Regs

Rev Proc 2015-20, 2015-9 IRB; IR 2015-29   In a Revenue Procedure and News Release, IRS has created a number of special procedures that will allow small businesses (under $10 million of assets or $10 million or less of gross receipts) to more easily adopt the tangible property regs that were issued in 2013. These […]

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No-rule guidance calls attention to uncertain aspects of popular estate planning tool

No-rule guidance calls attention to uncertain aspects of popular estate planning tool

Rev Proc 2015-37, 2015-26 IRB In a Revenue Procedure, IRS has ruled that it will no longer provide a ruling letter that assets in a grantor trust will receive a Code Sec. 1014 basis adjustment on the death of the owner where those assets aren’t included in the owner’s estate. Practitioners have speculated that this […]

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IRS amends & expands pre-approved plan program and extends application date

IRS amends & expands pre-approved plan program and extends application date

Rev Proc 2015-36, 2015-25 IRB In a Revenue Procedure, IRS has issued updated procedures for issuing opinion and advisory letters regarding the acceptability of the form of pre-approved plans under Code Sec. 401, Code Sec. 403(a) and Code Sec. 4975(e)(7) . The changes include an expansion of the scope of the pre-approved program. IRS has […]

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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