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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...
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...
Perhaps unsurprisingly to many California residents, the IRS has recently stepped up its efforts with regard to audits of the wealthiest Americans. The largest increase was for those taxpayers who make more than $10 million per year, although significant increases...
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...
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...
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...
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,...
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...
The California Franchise Tax Board (FTB), recently released Legal Guidance Division 2012-03-02 where it addressed the following question: Can a taxpayer make a valid single sales factor (SSF) election and also report tax computed without the election in order to avoid...
The IRS deadline for filing your tax return for 2011 is rapidly approaching, which means more people are becoming concerned about receiving that dreaded audit. Recently, we mentioned how the IRS is increasingly turning to so-called unreal audits ("Audits may not be...
