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IRS establishes program for rulings on significant issues

The IRS is reinstating the practice of issuing these letters in response to numerous informal comments from taxpayers and practitioners regarding the time required to process letter ruling requests and the scope of those requests.

Hedge funds: Tax structuring, planning, and compliance

Hedge funds may face tax issues of entity structuring, carried interest, management fee waivers, and trading-related rules. This article highlights planning strategies and compliance considerations as the IRS continues to increase its scrutiny of these investment vehicles.

Does an EIN/name mismatch invalidate a refund claim?

Arguments using the ‘informal claim doctrine’ and/or a taxpayer assistance order with the Taxpayer Advocacy Service may help taxpayers whose refund claims are stymied by a mismatch caused by an incorrect employer identification number.