In an Action On Decision (AOD), the IRS announced that it will acquiesce, in the result only of a decision in which the U.S. District Court held that a decedent's estate was entitled to a refund of deficiency assessed on contingent bequests. An AOD is a formal...
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IRS Chief Counsel Issues Guidance on the Economic Substance Doctrine
IRS Notice CC-2012-008 announces new Chief Counsel Coordination Procedures for asserting the economic substance doctrine, which was recently codified in Internal Revenue Code Section 7701(o). The notice is intended to ensure that the economic substance doctrine is...
IRS Commissioner Will Leave in November, Recounts Offshore Initiatives
Internal Revenue Service (IRS) commissioner, Douglas Shulman, said he doesn't intend to stay in the job after his five-year term expires in November. "My plan is to leave at the end of my term," he said during a question-and-answer session today at the National Press...
Losses from Indirect Investment of Funds Used to Operate a Ponzi Scheme are Theft Losses.
In a recently released legal memorandum, the Internal Revenue Service (IRS) ruled that taxpayers' losses resulting from investments in funds that were used to operate a Ponzi scheme are theft losses under § 165, even though the taxpayers invested through...
IRS Criminal Investigation Statistics
The IRS has published the new 2011 Data Book, which is available here. The book contains various interesting statistics relating to the IRS's criminal investigation function.Table 18, Criminal Investigation Program, by Status or Disposition, Fiscal Year 2011 is...
IRS Issues Grants Relief to Some MF Global Victims
The IRS just announced penalty relief for any farmers who had to file their return after March 1 due to delays associated with the MF Global bankruptcy case. This new release indicates the magnitude and far-reaching implications associated with untangling MF Global's...
IRS regulations and mortgage modifications
Many California residents may have heard of the multi-state settlement that was reached recently with many of the nation's largest lenders. The settlement includes a provision under which lenders will reduce a portion of the principal on some mortgages. However,...
Advance Pricing Agreements and Competent Authority
The IRS is seeking public comment in advance of issuing updated published guidance with respect to requests for Advance Pricing Agreements and Competent Authority assistance. The IRS announced certain organizational and administrative changes and...
IRS Recruiting Talent To Crack Down On Transfer Pricing
Reuters is reporting that despite the Internal revenue Agency's (IRS) 2012 fiscal budget cut of 2.5%, newly appointed Transfer Pricing Director, Samuel Maruca, is recruiting talent to crack down on companies that shift their profits from country to country in order to...
Deadline is approaching for overseas residents to file income tax returns
U.S. citizens and resident aliens residing overseas or those serving in the military outside the U.S. on April 17, 2012 have until June 15, 2012 to file their federal income tax returns. For information on forms, world-wide income, foreign earned income exclusion and...
