On December 22, 2022, the Internal Revenue Service (IRS) finalized changes to Schedule UTP, Uncertain Tax Position Statement, and Instructions for Schedule UTP. Proposed changes to Schedule UTP and the UTP Instructions were...more
On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more
When we previously wrote about the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS), we explained that the IRS generally must submit proposed refunds in...more
Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more
In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would...more
The Internal Revenue Service released a Q&A on Notice 2020-18 to clarify the relief available to taxpayers during the Coronavirus (COVID-19) pandemic. The Q&A offers important new details on the federal income tax filing and...more
3/28/2020
/ Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
Employee Contributions ,
Estate Tax ,
Filing Deadlines ,
Gift Tax ,
Income Taxes ,
Installment Agreements ,
IRS ,
Relief Measures ,
Shareholders ,
Tax Returns ,
Time Extensions
On March 20, 2020, the Internal Revenue Service expanded its relief for taxpayers in light of the Coronavirus (COVID-19) pandemic. All federal income tax payments and federal income tax returns that were due April 15, 2020,...more
On March 13, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. We...more
The Large Business and International Division of the Internal Revenue Service (IRS) developed the Compliance Assurance Process (CAP) program to improve large corporate taxpayer compliance with US federal tax obligations...more
On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
4/18/2019
/ Arms Length Transactions ,
Audits ,
Base Erosion Tax ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Entities ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Banks ,
Offshore Funds ,
Transfer Pricing
Each New Year, many of us look back on the previous year’s activities, and determine what we want to accomplish in the coming year – lose weight, start exercising, read more tax articles, etc. The Internal Revenue Service...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury
On February 28, 2014, the Internal Revenue Service Large Business and International Division released updated guidance for examiners incorporating and superseding two directives relating to Information Document Requests. The...more