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Revenue Procedures

IRS announces ACA premium credit and individual mandate indexing adjustments

IRS announces ACA premium credit and individual mandate indexing adjustments

Rev Proc 2016-24, 2016-16 IRB In a Revenue Procedure, IRS has provided indexing adjustments that are to be used in applying various Affordable Care Act (ACA) provisions under Code Sec. 36B (the premium tax credit) and Code Sec. 5000A (the individual mandate) for 2017. Included in the adjustments are: the 2017 Applicable Percentage Table in […]

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

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

Rev Proc 2016-18, 2016-16 IRB 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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IRS explains how retirement plan administrators request waiver of electronic filing requirement

IRS explains how retirement plan administrators request waiver of electronic filing requirement

Rev Proc 2015-47, 2015-39 IRB In a Revenue Procedure, IRS has set forth procedures for plan administrators of retirement plans (or, in certain situations, employes maintaining retirement plans) that are required to file electronically Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, and Form 5500-EZ, Annual Return of One-Participant (Owners and […]

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Modification of automatic accounting method change rules for tangible property dispositions

Modification of automatic accounting method change rules for tangible property dispositions

Rev Proc 2014-54, 2014-41 IRB In a Revenue Procedure, IRS has provided guidance on making automatic accounting method changes that coordinates with recently issued final regs on dispositions of tangible property. Among other things, IRS made a number of modifications to Rev Proc 2011-14’s Appendix and allowed for a late partial disposition election under Reg. […]

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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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New accounting method change rules for certain royalties, vendor chargebacks, etc.

New accounting method change rules for certain royalties, vendor chargebacks, etc.

In a Revenue Procedure 2014-33, 2014-22 IRB, IRS has provided exclusive procedures for a taxpayer’s obtaining its automatic consent to: (1) change its method of accounting for certain royalties; (2) change its method of accounting for “sales-based vendor chargebacks;” or (3) change its simplified production method or simplified resale method for costs allocated only to […]

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What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

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IRS provides extension for small estates that want portability

IRS provides extension for small estates that want portability

In Revenue Procedure 2014-18, 2004-7 IRB, IRS has provided a procedure under which estates of decedents that died before Jan. 1, 2014, that fall below the dollar threshold for having to file an estate tax return, and that want to elect to make the estate tax portability exclusion, can get an automatic extension of time […]

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IRS updates procedures for requesting approval for employment tax authorizations

IRS updates procedures for requesting approval for employment tax authorizations

In Revenue Procedure 2013-39, 2013-52 IRB, in conjunction with new final regs issued on the same day, IRS has described and updated the procedure for requesting its authorization for a person to act as an agent under Code Sec. 3504 for purposes of Chapters 21 (Federal Insurance Contributions Act, or FICA), 22 (Railroad Retirement Tax […]

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IRS 2013 updated procedures for Exempt Organizations

IRS 2013 updated procedures for Exempt Organizations

IRS recently announced a series of updated procedures that are of interest to taxpayers and their representatives in the Exempt Organizations area.  Here is the short list. Rev. Proc. 2013-4 Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters related to sections of the Code […]

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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