The IRS issued final regulations requiring taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS.
IRS Practice & Procedure
Advising Clients Regarding Erroneous Tax Return Positions: Part II
This article discusses what tax practitioners must do if their client fails to heed their advice whan an error is found on a tax return and what to do when the error is attributable to the tax practitioner’s own advice.
A Closer Look at the IRS’s Targeting of Tea Party and Other Groups for Review
In a report issued on May 14, TIGTA found that the IRS used inappropriate criteria to single out for review certain applications for tax-exempt status.
Using the First-Time Penalty Abatement Waiver
This article explores the IRS first-time penalty abatement waiver and explains how to help clients remove certain penalties using it.
Final Regs. Permanently Extend Period to Receive Disclosure Authorization
The IRS issued final regulations extending from 60 days to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees.
IRS Will Get Search Warrants When Seeking Taxpayer Emails
The IRS announced a new policy regarding how it will request emails from internet service providers.
Interim IRS Chief Issues Initial Report on Sec. 501(c)(4) Controversy
Acting IRS commissioner Daniel Werfel issued a report on the plans to reform the IRS to avoid inappropriate targeting of taxpayers applying for Sec. 501(c)(4) social welfare organization status.
IRS Controversy Could Cause Tax-Exempt Processing Slowdown
Prepare for a slowdown in work handled by the IRS Exempt Organizations Division in the wake of the recent controversy involving the processing of certain applications for tax exemption, says the division’s former head.
TIGTA Criticizes the IRS on Conference Overspending
TIGTA issued a report detailing the IRS’s wasteful spending on conferences.
IRS Issues “No-Rule” Orders on Several Sec. 355 Transactions
The IRS recently put an abrupt halt to its ruling practice with respect to several transactions in the Sec. 355 area for which rulings had previously become routine.
Advising Clients Regarding Erroneous Tax Return Positions: Part I
This article examines the two somewhat different versions of the rule on advising clients regarding erroneous tax return positions—one applied by the AICPA and the other by the IRS.
Appeals Court Refuses to Lift Injunction in Return Preparer Regulation Case
The IRS lost another round in its court battle over its plan to regulate tax return preparers when the D.C. Circuit denied its motion to stay an injunction halting the IRS’s return preparer regulation program.
Tax Court Reverses Its Position on Valuation Misstatement Penalty; Supreme Court Agrees to Hear Case on the Issue
The Tax Court held that a taxpayer may not avoid application of the gross valuation misstatement penalty by conceding that adjustments made in an IRS FPAA notice were correct on grounds unrelated to valuation or basis.
IRS Expands Identity Theft Law Enforcement Assistance Program
The IRS has expanded its Law Enforcement Assistance Program on identity theft to all 50 states and the District of Columbia.
Promoting Fictitious Bonds for Tax Payments Leads to Conviction for “Sovereign Citizen”
A proponent of the “sovereign citizens” movement has been convicted of conspiracy to defraud the United States through a series of seminars in which attendees were taught to pay their federal income taxes by filing fictitious bonds.
Suspension of Tangible Property Capitalization Issue Examinations Extended
The IRS posted an updated directive for field examinations on the repair vs. capitalization issue that extends the suspension of examinations.
Oklahoma Tornado Victims Get Tax Filing and Payment Extensions
The IRS announced relief from filing and payment deadlines for victims of Monday’s destructive tornadoes in Oklahoma.
Final Rules Require EIN Updates
The IRS issued final regulations requiring taxpayers that obtain EINs to update their information with the IRS.
Statute of Limitation Tolled by Fraudulent Tax Returns
The Second Circuit held that the filing of fraudulent tax returns for a corporation by an accountant to embezzle money that was owed to the IRS was an intentional evasion of taxes that tolled the statute of limitation on assessment.
Prop. Regs. Allow Material Advisers to Request Extension
The IRS issued proposed regulations governing the penalty for failure of material advisers to provide lists of advisees in reportable transactions.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.