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Economic Substance Guidance Issued to IRS Examiners

The IRS Large Business and International (LB&I) Division issued guidance to examiners on the newly codified economic substance doctrine limiting the application of penalties relating to the doctrine.

100,000 Preparers Did Not Comply with PTIN Rules

The IRS announced that it has identified approximately 100,000 tax return preparers who did not comply with the new rules for preparer tax identification numbers (PTINs), and it is sending them letters informing them of the problem.

Restricted Interest and Common Errors Made by the IRS

The Internal Revenue Code allows the IRS to charge interest when a taxpayer does not pay all required taxes by the due date of the return. The Code also requires the IRS to pay interest on refunds in certain circumstances. This item discusses the many nuances related to the computation of interest that tax professionals should be familiar with.

IRS Matching Program for Forms 8023 and 8883 May Result in Invalid Sec. 338 Election

The IRS recently launched a program to match the filing of Form 8023, Elections Under Section 338 for Corporations Making Qualified Stock Purchases, by a foreign purchasing corporation acquiring a foreign target, with Form 8883, Asset Allocation Statement Under Section 338, to report the effect of the Sec. 338 election.

IRS Challenges Noted by Oversight Board

The IRS Oversight Board described the IRS’s performance during FY 2010, its progress in meeting its goals, and the challenges the IRS has faced in recent years in administering new tax laws enacted to provide economic relief during the recession.

Truncated Social Security Number Program Extended

The IRS announced that it is extending and modifying a pilot program allowing filers of certain paper information returns to truncate the payee’s Social Security number on the payee statement.

Memo Addresses Treatment of Fraudulently Altered Returns

The Office of Chief Counsel advised on a number of issues regarding returns where a preparer, after issuing the taxpayers refund anticipation loans, increased the amount of the charitable contribution deductions claimed on the returns without the taxpayers’ knowledge or consent to increase the refund received from the IRS.

Why the Flap Over a VAT?

This item provides a view of issues that would need to be considered if the United States were to consider adopting a value-added tax (VAT) at the federal level.