Audits Internal Revenue Service

News & Analysis as of

Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

I Know My Rollover is Late, but It’s Okay. Trust Me.

As retirement plan professionals know, certain distributions from plans and IRAs to taxpayers can be rolled over to another plan or IRA within 60 days. Of course, sometimes 60 days is just not enough and the IRS recognizes...more

Compensation and Benefits Insights – September 2016

New Guidance Affects Wellness Program Design - Over the last several months, the Equal Employment Opportunity Commission (“EEOC”) and the Internal Revenue Service (“IRS”) have provided additional guidance regarding the...more

Opting-In: Treasury Regulations Provide Rules for Electing into the New Partnership Audit Regime Early

As reported in a prior Sutherland Legal Alert, the Bipartisan Budget Act of 2015 (the 2015 Budget Act) makes significant changes to the procedural rules governing federal income tax audits and judicial proceedings that apply...more

How, When and Where a Partnership Can Elect into the New Partnership Audit Regime

On August 4, 2016, the IRS published a temporary regulation for partnerships wanting to elect into the new partnership audit procedural rules that were enacted in the Bipartisan Budget Act of 2015 on November 2, 2015. Treas....more

IRS Issues Guidance to Partnerships Opting-In to New Partnership Audit Regime

The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more

IRS Issues Guidance to Partnerships Opting-In to New Partnership Audit Regime

The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more

New Regulations for Partnerships Electing into New Partnership Audit Rules Early

New partnership audit rules enacted into law on November 2, 2015 (the “New Partnership Audit Rules”) generally call for all determinations of adjustments to income and payments of tax pursuant to a partnership tax audit,...more

Healthcare Newsletter: Volume 6, Number 1

Recent Developments in Mental Health Benefit Denials - The Mental Health Parity and Addiction Equity Act (Parity Act) requires health plans to provide the same coverage for mental health conditions as they provide for...more

A Blueprint for Maintaining an Individually Designed Qualified Plan after the IRS’s Determination Letter Program Cutback

In Depth - On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017,...more

New IRS Audit Rules: Is Your Healthcare LLC Ready?

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

Massachusetts Court Issues 'True Debt' Decision

On June 8, the Massachusetts Appeals Court once again denied a taxpayer’s claimed deductions from the income and net worth tax base of the corporate excise tax. In a decision that will be a disappointment for taxpayers...more

As Affordable Care Act Enforcement Looms, Some Lessons Learned From Massachusetts

As the ACA audit era approaches, many employers are wondering: what will happen? What sorts of documentation will the IRS request? What industries will be targeted? And what can employers do to prepare? In this post, I...more

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act...more

New Partnership Audit Rules Will Require Amendment of All Partnership Agreements by 2018

On November 2, 2015, Congress passed the Bipartisan Budget Act of 2015, Section 1101 of which repeals the long-standing current rules for IRS audits of partnership entities and replaces those rules with a new centralized...more

IRS Audit Techniques Guide Provides Helpful Reminders for Sponsors of NQDC Arrangements

Last summer the Internal Revenue Service updated its Audit Techniques Guide (“ATG”) for nonqualified deferred compensation arrangements. While the ATG provides little instruction on how the IRS will review nonqualified...more

Have You Reviewed your Employee Handbook for Affordable Care Act Compliance?

Even though the first year of the Affordable Care Act’s employer mandate is in effect and fully phased-in, it has been our experience that few employers have bothered to review their employee handbooks to reflect the ACA. ...more

Partnerships Must Respond to New Audit Rules

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

Changes to IRS Partnership and LLC Audit Rules

Recent history has seen a proliferation of health care organizations—including tax-exempt organizations, for-profit companies, and physician practice groups—that have joined together to take advantage of different synergies...more

New Partnership Tax Audit Rules

The Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such...more

Like Santa Claus, the IRS Keeps a List of Who Has Been Naughty or Nice: It Is the Time of Year When the IRS’s Naughty List Gets...

Every year, around the April 15 individual tax return filing deadline, a story appears in the press highlighting the tax woes of famous people. The Government undoubtedly issues these press releases to encourage taxpayers to...more

IRS Sets Short Fuse for Comments, Guidance on New Partnership Audit Rules

As if it wasn’t going to be busy already, the Internal Revenue Service (“IRS”) has set Tax Day, April 15, 2016, as the due date for comments on significant new partnership audit rules. This new law, which was enacted as part...more

Partnership Audits of Private Equity Firms on the Rise

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

Did the Tribunal Expand the Jurisdiction of the Division of Tax Appeals?

In Matter of Grand Central JT VT (March 10, 2016), the Tax Appeals Tribunal decided a fairly routine tax case as to whether the taxpayer maintained adequate books and records in a sales tax audit and whether the Audit...more

155 Results
|
View per page
Page: of 7
JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×