The November 26, 2018, release by the Internal Revenue Service of proposed regulations (REG-106089-18) related to IRC § 163(j) has provided some clarity for federal income taxpayers. But the regulations’ treatment of federal consolidated groups gives... Read More
On this edition, Leslie Schneider of Ivins, Phillips & Barker, Chartered, discusses the status of last-in-first-out (LIFO) tax accounting and international financial accounting standards (IFRS). Mr. Schneider also analyzes the treatment of sales-based... Read More
By Karen Yip, LexisNexis Federal & International Tax Analyst The IRS requires the Report of Foreign Bank and Financial Accounts, TD F 90-22.1 (commonly known as the Foreign Bank Account Report, or "FBAR"), when a U.S. person has a financial... Read More
By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions... Read More
The IRS revised the Instructions for Schedule UTP in early February, but one thing that it did not change was the definition of the concise description required to accompany each uncertain tax position. The IRS later publicly expressed concerns over the... Read More
By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final... Read More
The Record, a California legal publication, reports on oral argument in a case involved the act of production doctrine which says, in effect, that although the contents of documents may not be privileged, a witness under compulsion to produce the documents... Read More
The Internal Revenue Service has released a new set of frequently asked questions (FAQs) on the requirement to provide notice to participants in pension, 401(k), 403(b), and other retirement plans who have terminated employment with the plan sponsor,... Read More
In a decision that could dramatically change collection due process, the First Circuit Court of Appeals held that the standard of review applied to collection due process cases by the Tax Court for more than a decade is incorrect. In Dalton v. Commissioner... Read More
In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More
Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil... Read More
In United States v. DeMuro, ___ F.3d ___, 2012 U.S. App. LEXIS 8094 (3d Cir. 2012) , enhanced opinion available to lexis.com subscribers, (Non-subscribers can download the unenhanced official opinion here ), the Demuros, husband and wife, were convicted... Read More