In the introduction to her recent report to Congress, IRS National Taxpayer Advocate (NTA) Nina Olson warns that recent expansion of the IRS mission is straining some of its core capabilities.
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IRS Practice & Procedure
IRS Issues Interim Report on the Colleges and Universities Compliance Project
The IRS recently issued an interim report on the Colleges and Universities Compliance Project that was initiated by the Exempt Organizations (EO) function of the Tax Exempt and Government Entities (TE/GE) division.
Small and Medium Enterprises Should Consider Making Advance Pricing Agreements
This item discusses the procedures that small and medium-size enterprises can use to obtain advance pricing agreements with the IRS so they can minimize their exposure to intercompany pricing adjustments on audit.
Is Your Contractor Really Independent?
This item provides an overview of the factors examined by the IRS and offers insight into how to better secure independent contractor status.
Accuracy-Related Penalty Applied Despite Reliance on Adviser
The Tax Court held that a corporation was liable for an accuracy-related penalty for a substantial understatement of tax related to a joint venture transaction even though the corporation had received an opinion from a national accounting firm that the transaction was not taxable.
IRS Moves Forward with Preparer Registration Plan
On August 19, the IRS issued proposed regulations that would put into place many of the parts of its plan to register and regulate tax return preparers. This item reviews those proposed regulations and their possible impact on tax professionals.
Tax Return Due Diligence: Basic Considerations
This article examines the rules of due diligence and the importance of tax professionals understanding these rules and proactively adapting to them in a practical manner.
IRS Changes Name, Expands Focus of LMSB Division
The IRS announced that it is reorganizing and changing the name of its Large and Mid-Size Business division as part of its ongoing effort to focus more on international tax compliance. Starting October 1, 2010, the division will be known as the Large Business and International (LB&I) division.
IRS Will Stop Providing Debt Indicators; Exploring Ways for Taxpayers to Use Refunds to Pay Preparers
The IRS announced that it will stop providing “debt indicators” to tax preparers and associated financial institutions.
Final Regs. Released for Payment Card and Third-Party Network Information Reporting
The IRS has issued final regulations regarding the new information reporting requirement under Sec. 6050W for payment card and third-party network transactions.
IRS Activates New PTIN System
The IRS deployed a new preparer tax identification number (PTIN) registration system September 28 as a component of its initiative to register and regulate paid tax return preparers.
IRS Says It Won’t Give Advance Guidance on Transactions Under Codified Economic Substance Doctrine
The IRS issued its first guidance on the newly codified economic substance doctrine.
Treasury Announces Low-Cost Financial Account Program for Taxpayers
Treasury announced the launch of a pilot program to provide taxpayers with access to low-cost financial accounts.
IRS Proposes PTIN Fees
The IRS proposed to begin charging all authorized tax preparers a $50 user fee to obtain or renew annually a preparer tax identification number (PTIN).
IRS Launches Gulf Oil Spill Hotline
The IRS announced that it has set up a special toll-free telephone line for taxpayers affected by the oil spill in the Gulf of Mexico.
IRS Announces Phase-in of Mandatory E-Filing
The Worker, Homeownership, and Business Assistance Act mandates e-filing by almost all return preparers; it requires any return preparer who files more than 10 individual income tax returns per year to e-file those returns, starting in 2011.
Tax Lien Attached to Property Transferred in Divorce
The IRS Office of Chief Counsel advised a member of the National Taxpayer Advocate Office that a tax lien attached to property that a husband transferred to his wife in a divorce settlement where the quitclaim deed conveying the property was not registered prior to the filing of a Notice of Federal Tax Lien.
AICPA Testifies at IRS Hearing on User Fee Regulations
Edward Karl, the AICPA’s vice president of taxation, testified on August 24 at an IRS hearing on proposed regulations relating to the user fee aspect of the Service’s proposal to require all paid tax return preparers to obtain a preparer tax identification number (PTIN) and use it on all tax returns after December 31, 2010.
IRS Finalizes Regs on Tentative Carryback Adjustments
The IRS released final regulations under Sec. 6411 providing guidance on the computation and allowance of tentative carryback adjustments
IRS Preparer Registration Plan Moves Forward
The IRS issued proposed regulations that would put into place many of the parts of its plan to register and regulate tax return preparers.
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.
