John Robert
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IRS Expands Section 355 Ruling Practice
By John Robert, Kevin Spencer and Macdonald Norman on Oct 6, 2017
Posted In IRS Guidance, Uncategorized
On September 21, the Internal Revenue Service (IRS) released Revenue Procedure 2017-52 which introduces an 18 month pilot program expanding the scope of the IRS’s ruling practice with respect to distributions under Internal Revenue Code (Code) Section 355. Prior to Revenue Procedure 2017-52, the IRS had determined that it would not issue letter rulings on...
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Sixth Circuit Sets Limits on the Application of the Substance-Over-Form Doctrine
By David Sherwood and John Robert on Feb 21, 2017
Posted In Appellate Courts, Uncategorized
The judicial substance-over-form doctrine provides the IRS with the ability to set aside carefully orchestrated tax planning arrangements to treat a transaction consistent with its substance. However, the doctrine does not give the Service carte blanche to deny tax benefits. In Summa Holdings, Inc. v. Commissioner, No. 16-1712 (available here), the Sixth Circuit overturned the...
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IRS Adds More Enforcement Employees
By John Robert and Kevin Spencer on May 5, 2016
Posted In IRS Audits, Uncategorized
In an internal memo to agency employees, Internal Revenue Service (IRS) Commissioner John A. Koskinen announced the IRS’s intention to hire between 600 and 700 enforcement personnel. It is estimated that between 2010 and the end of 2016, the IRS will have lost more than 17,000 employees, 5,000 from the enforcement area. The hiring, which...
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