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IRS Practice & Procedure

Auditor Guidelines on Business Travel and Meal Per Diems after Rev. Rul. 2006-56

An IRS examination memorandum provides guidelines to examiners auditing excess per-diem payments in light of Rev. Rul. 2006-56. The issue involves taxpayers who pay reimbursement allowances to employees for travel expenses in an amount exceeding the Federal per-diem rate, without treating such excess amounts as wages for employment tax purposes.

Online Payment Agreements

According to IR-2007-68, the IRS has enhanced the interactive Online Payment Agreement (OPA) application. OPAs allow eligible taxpayers (or their authorized representatives) to self-qualify and apply for installment agreements, receive immediate notification of approval and establish paperless direct debit agreements. The Service estimates that over 75% of taxpayers eligible to

Withholding Requirements for Nonresident Directors’ Fees

Editor: Terence E. Kelly, CPA Multinational corporations are taking advantage of worldwide expertise to adapt to the changing economic landscape. Corporations frequently have foreign nationals on their boards of directors. This item will assist U.S. companies and/or tax professionals dealing with the taxation of such directors. Cross-Border Example A resident

Offers in Compromise

According to IR-2007-50, the IRS has issued a revised application for an offer in compromise (OIC) (Form 656). An OIC is an agreement between a taxpayer and the Service that resolves a tax liability. Under certain circumstances, the IRS has the authority to settle Federal tax liabilities by accepting less

Tax-Strategy Patents and the Tax Gap

Two tax policy topics have recently been getting increased attention: tax-strategy patents and the tax gap. The AICPA has been taking an active role in the debate on each topic. This column summarizes the issues and the AICPA’s involvement. Tax-Strategy Patents The patentability of tax strategies is a growing concern

Superseding Return Filed on Extended Due Date Starts SOL

Editor: John L. Miller, CPA The general statute of limitations (SOL) for assessment found in Sec. 6501 gives the IRS three years to assess tax after a return has been filed, beginning on the date that a valid Federal tax return is deemed filed. A return filed prior to the

New Requirements for 2006 Business Filers

Editor: John L. Miller, CPA When filing 2006 corporate tax returns, many businesses will encounter new IRS requirements that significantly affect how they file. Some filers of Forms 1120, U.S. Corporation Income Tax Return, and 1120S, U.S. Income Tax Return for an S Corporation, will be covered by phase two

Sec. 199 Deduction

The Service has released a new “Industry Director Directive” on the Sec. 199 domestic production activities deduction (DPAD). The directive, along with an associated document entitled “Minimum Checks for Section 199; Law and Explanation,” details the minimum audit checks IRS examiners are expected to complete when scrutinizing a corporation’s Sec.

Extended Filing Deadline

According to IR-2007-15, taxpayers have until April 17, 2007 to file their 2006 returns and pay any taxes due, because April 15, 2007 is a Sunday and the following day, Monday, April 16, is Emancipation Day, a legal holiday in Washington, DC. Thus, the entire country has an April 17

Online AMT Calculator

According to IR-2007-18, the IRS has updated its Internet-based calculator to help taxpayers determine whether they owe the alternative minimum tax (AMT). The online AMT Assistant is an automated version of Worksheet to see if you should fill in Form 6251, Alternative Minimum Tax. The worksheet, contained in the Form

INDIVIDUALS

Current Developments in Taxation of Individuals: Part 1

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.

Tax Clinic

Planning for domestication transactions

Planning for new charitable contribution limits

Effect of the new pro rata share rules

Determining when a debt instrument has zero basis

Structuring partnership mergers