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What’s Next for International Reporting Post-Farhy? | JD Supra
JD Supra· 5 days agoLast April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating for ...
Pro-bono legal service launched in Calgary for Indigenous people facing criminal charges
CBC via Yahoo News· 2 days agoA new Calgary organization aimed at addressing the overrepresentation of Indigenous people in the...
...Not Abuse Discretion in Denying Request for Penalty Abatements and Consideration of Collection...
Bloomberg Law· 19 hours agoSettlement officer (SO) with the IRS Independent Office of Appeals (Appeals) did not abuse her discretion in determining Petitioner was not entitled to abatement of previously assessed additions ...
IRS News Release: New IRS Team Established, New Guidance Issued to Stop Partnerships From Using...
Bloomberg Law· 2 days agoA new dedicated group in the IRS Office of Chief Counsel is being established to specifically focus on combating the abusive use of partnerships, the IRS announced. The office will ...
‘A hellscape’: dire conditions in Gaza leave a multitude of amputees - The Boston Globe
The Boston Globe· 2 days agoThe crude surgery was captured in a video shared widely online, a grim emblem of the agonizing choices that have been repeated countless times in a war that has ravaged Gaza Strip residents’ ...
IRS PLR: Disregarded Entity Election Extension Granted (IRC §7701)
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Section 7701, granting a 120-day extension of time to file Form 8832, Entity Classification Election, to elect to be classified as ...
IRS Rev. Rul.: Economic Substance Doctrine for Partnership Related-Party Basis Adjustments (IRC...
Bloomberg Law· 2 days agoUsing three example situations, Taxpayers are advised of the IRS’s position challenging certain partnership related-party transactions under the codified economic substance doctrine in I.R.C. §7701(o), the IRS stated. The ruling ...
IRS PLR: Extension Granted to File Form 8996 for Election to Self-Certify as QOF (IRC §1400Z)
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Section 1400Z, and Treasury Regulation Section 301.9100, regarding extensions of time to self-certify as a Qualified Opportunity Fund (QOF). [PLR 202424003] ...
IRS PLR: Extension of Time Granted to Make Qualified Terminable Interest Property Election (IRC...
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Sections 2056 and 2652, and Treasury Regulations Section 301.9100, regarding extensions of time to make a qualified terminable interest property (QTIP) ...
IRS PLR: Extension Granted to Foreign Entity to Elect Disregarded Entity Treatment (IRC §7701)
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Treasury Regulation Sections 301.7701 and 301.9100, granting a foreign entity an extension of time to elect to be treated as a ...