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Withholding requirements

Court clarifies Supreme Court rule that IRS precisely spell out withholding requirements

Court clarifies Supreme Court rule that IRS precisely spell out withholding requirements

Netjets Large Aircraft, Inc., (DC OH 11/12/2015) 116 AFTR 2d ¶ 2015-5420 A district court has interpreted a Supreme Court decision as requiring that IRS provide withholding and collection agents with precise and not speculative guidance as to their withholding or collection obligations and has held that IRS did not meet that requirement with respect […]

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IRS updates qualified intermediary (QI) withholding agreement and provides QI rules

IRS updates qualified intermediary (QI) withholding agreement and provides QI rules

Rev Proc 2014-39, 2014-29 IRB. In a revenue procedure, IRS has issued an updated version of the Qualified Intermediary (QI) agreement, i.e., the agreement that may be entered into by foreign intermediaries and IRS with respect to withholding responsibilities. The revenue procedure also provides guidance for entering into a QI withholding agreement and application procedures […]

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IRS Chief Counsel Advice addresses income sourcing and withholding for payments to foreign distributors

IRS Chief Counsel Advice addresses income sourcing and withholding for payments to foreign distributors

In Chief Counsel Advice (CCA) 2013-43020, IRS has determined the tax treatment of and withholding requirements applicable to payments made by a multi-level U.S. marketing company (Taxpayer) to foreign distributors for facilitating sales of Taxpayer products to lower-tier distributors in the foreign distributors’ sponsorship chain. The CCA concluded that earnings of a foreign distributor based […]

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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