Documentation Internal Revenue Service

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"Notice 2013-79: IRS Proposes Revisions to Advance Pricing Agreement Requests"

On November 22, 2013, the IRS issued Notice 2013-79, which contains draft Revenue Procedures applicable to Advance Pricing Agreements (APAs). The IRS requested comments by March 10, 2014. The Revenue Procedure and the...more

IRS Disregards Loans To Closely-Held Coporation

It is fairly commonplace for owners of closely held corporations to loan funds to their corporation without full loan documentation....more

No Records is Not an Acceptable Excuse

Often taxpayers who have not filed Reports of Foreign Bank or Financial Accounts (FBAR’s) will claim that they do not have records of their offshore accounts, because the accounts are maintained by third parties. In many...more

IRS Proposes Regulations Regarding Community Health Needs Assessments for Charitable Hospitals

The IRS has released its proposed regulations [PDF] detailing the requirements for conducting and reporting Community Health Needs Assessments (CHNAs) under section 501(r)(3) of the Internal Revenue Code, which were...more

Treasury Issues Final FATCA Regulations

Introduction - On January 17, 2013, the Department of the Treasury (“the Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Regulations”) under Sections 1471 through 1474 of the...more

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