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Brian Moore focuses his practice on US and international tax matters. Read Brian Moore's full bio.

Final Section 468A Regulations Issued at Last


By and on Sep 11, 2020
Posted In IRS Guidance, Tax Reform

On September 4, 2020, the Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) published in the Federal Register final regulations under section 468A of the Internal Revenue Code (the Code) that address three issues raised by the nuclear electric industry concerning qualified nuclear decommissioning funds (“qualified funds”). These final regulations conclude a many...

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IRS Targets Private Foundations That May Be Used by Wealthy Taxpayers in Tax Planning


By , and on Jun 26, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform, Tax Refunds

​In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the use of private foundations for tax planning. Ms. Tamera Ripperda, who is the commissioner of the Tax Exempt and Government Entities (TEGE) Division and previously served as the industry director for the Global...

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Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement


By , and on Jun 10, 2020
Posted In IRS Appeals, IRS Audits, IRS Guidance, Settlements, Trial Courts

A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency. In Howe v. Commissioner, T.C. Memo 2020-78, the Tax Court held that equitable estoppel did not bind the Commissioner to an...

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Tax Court Holds IRS Chief Counsel Attorneys May Make Initial Penalty Determination


By , and on Jun 8, 2020
Posted In Appellate Courts, IRS Appeals, IRS Guidance

In general, section 6751 requires that a supervisor give written approval before penalties can be asserted against a taxpayer. In Koh v. Commissioner, T.C. Memo. 2020-77, authored by the US Tax Court’s (Tax Court) most recent addition—Judge Travis Greaves—the Tax Court affirmed that an attorney from Internal Revenue Service (IRS) Chief Counsel may be authorized to...

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IRC 45Q Credit Under IRS Scrutiny: Government Finds Majority of Carbon Oxide Credits Improperly Claimed


By , and on May 6, 2020
Posted In IRS Guidance, Uncategorized

In response to a series of questions posed in a November 2019 letter from Senator Menendez (D-NJ), the Treasury Inspector General for Tax Administration (TIGTA) issued a letter on April 15, 2020, analyzing carbon oxide credits under Internal Revenue Code (IRC) section 45Q. For tax years between 2010 and 2019, TIGTA found that up to...

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You Can Now Submit Your Letter Rulings and Determinations to the IRS Electronically


By , and on May 1, 2020
Posted In IRS Guidance, Uncategorized

Rev. Proc. 2020-29 temporarily allows taxpayers to submit certain requests for letter rulings and determinations to the Internal Revenue Service (IRS) electronically. Electronic submissions will be permitted until the revenue procedure is superseded or modified, but taxpayers may still make paper submissions. Electronic submissions are permitted for requests for letter rulings, closing agreements, determination letters,...

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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19


By , , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.

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Taxpayer Victory in an IRC Section 199 Contract Manufacturing Case


By , and on Mar 24, 2020
Posted In Tax Refunds, Trial Courts, Uncategorized

Recently, the US Federal District Court for the Southern District of Iowa in Meredith Corp. v. United States, No. 4:17-cv-00385 (S.D. Iowa Mar. 20, 2020), held that a magazine publisher was entitled to refund of federal income tax based for the Internal Revenue Code (IRC) section 199 domestic production deduction based upon the printing services...

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IRS Provides Some Relief from Tax Payment (But Not Filing) Deadlines Due to COVID-19


By , , and on Mar 19, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS issued Notice 2020-17. The Notice declares that all taxpayers have been affected by the emergency...

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