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Weekly IRS Roundup September 21 – September 25, 2020


By on Oct 2, 2020
Posted In IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. September 21, 2020: The IRS released Announcement 2020-12 to detail information reporting requirements...

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IRS Issues Transition Tax Compliance Campaign


By , and on Nov 6, 2019
Posted In IRS Appeals, IRS Audits, IRS Guidance, Tax Reform, Uncategorized

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of several dozen compliance campaigns that LB&I has announced since the initial 13 campaigns were identified in 2017, and is...

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Weekly IRS Roundup August 26 – 30, 2019


By on Sep 3, 2019
Posted In IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019. August 26, 2019: The IRS released a Treasury Decision in which it issued correcting amendments to TD 9866 (i.e., the global intangible low-taxed income (GILTI) and Foreign Tax Credit Regulations...

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IRS Resumes Examinations of Stock Based Compensation in Cost Sharing Agreements


By , and on Aug 8, 2019
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized

On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock based compensation (SBC) in Cost Sharing Arrangements (CSAS). See here for IRS Notice of Withdrawal. The Directive was issued January 12, 2018, after the Tax Court’s...

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Weekly IRS Roundup May 6 – 10, 2019


By on May 13, 2019
Posted In Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue Procedure 75-50 in order to reflect technological advances. Revenue Procedure 75-50 provides guidelines to determine whether a private school...

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Weekly IRS Roundup April 15 – 19, 2019


By on Apr 22, 2019
Posted In IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15 – 19, 2019. April 16, 2019: The IRS issued Revenue Ruling 2019-12 providing monthly tables of prescribed rates under numerous Code sections, including the applicable federal rate for May. April 16, 2019: The...

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Second Circuit Weighs in on Tax Court’s Refund Jurisdiction


By , and on Apr 16, 2019
Posted In Appellate Courts, Tax Reform, Tax Refunds, Trial Courts, Uncategorized

Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s holding in Borenstein that the court lacked jurisdiction to order a refund of an undisputed overpayment made by the taxpayer. The case, which...

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Weekly IRS Roundup March 18 – 22, 2019


By on Mar 25, 2019
Posted In IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 18 – 22, 2019. March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on proposed regulations on hybrid arrangements under Sections 245A and 267A of the code. March 19,...

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Weekly IRS Roundup February 25 – March 1, 2019


By on Mar 4, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05, announcing the interest rates for underpayments and overpayments under section 6621 of the Code, applicable for the calendar quarter beginning...

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Weekly IRS Roundup February 18 – 22, 2019


By on Feb 25, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online resources for answering taxpayer questions, in light of high call volume during the period following Presidents Day. February 19,...

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