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IRS PLR: Consent to Make Retroactive Qualified Electing Fund Election Granted (IRC §1295)
Bloomberg Law· 21 hours agoThe IRS has published a private letter ruling on Section 1295, and Treasury Regulation Section 1.1295-3, regarding making a retroactive Qualified Election Fund (QEF) election. [PLR 202424001]
IRS PLR: Extension Granted to Foreign Entity to Elect Disregarded Entity Treatment (IRC §7701)
Bloomberg Law· 23 hours 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 ...
IRS Rev. Rul.: Economic Substance Doctrine for Partnership Related-Party Basis Adjustments (IRC...
Bloomberg Law· 1 day 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 ...
Alan Parker on Internal Revenue Code (IRC) | JD Supra
JD Supra· 1 day agoJD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations. This Privacy Policy describes how JD Supra ...
What’s Next for International Reporting Post-Farhy? | JD Supra
JD Supra· 4 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 ...
IRS PLR: Extension Granted to File Form 8996 for Election to Self-Certify as QOF (IRC §1400Z)
Bloomberg Law· 22 hours 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 202424019] ...
IRS Notice: Interest Rates, Yield Rates, Segment Rates for Pension Plan Minimum Funding (IRC §412)
Bloomberg Law· 21 hours agoUpdated guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under I.R.C. §417(e)(3), and the 24-month average segment rates under §430(h)(2), interest rate on 30-year ...
IRS PLR: Extension of Time for Application to Adopt, Change, or Retain Tax Year-End Denied (IRC...
Bloomberg Law· 21 hours agoThe IRS has published a private letter ruling on Section 9100 of the Treasury Regulations, denying the taxpayer’s request for an extension of time to file Form 1128, Application to ...
What Makes a Room a “Bedroom”?
Bob Vila via Yahoo News· 7 days agoThe Safety Issue When a space is to be labeled a bedroom or otherwise, safety is the primary deciding factor. The International Residential Code (IRC)...
IRS PLR: Extension of Time Granted to Make Qualified Terminable Interest Property Election (IRC...
Bloomberg Law· 22 hours 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) ...
