The IRS released for publication in the Federal Register final regulations (T.D. 9871) concerning the allocation by a partnership of foreign income taxes to partners. Specifically, the regulations concern the rules for allocations of “creditable foreign tax expenditures." The final regs adopt and finalize regulations that were proposed in 2016 with certain minor clarifications. To … Continue reading IRS Issues Final Regs: Partnership allocations of foreign income taxes to partners
To date, LB&I has announced a total of 59 campaigns. The campaigns described below were identified through LB&I data analysis and suggestions from IRS employees. LB&I's goal is to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources. The new campaigns are: S Corporations Built in … Continue reading The IRS Large Business and International division (LB&I) announces the approval of six additional compliance campaigns (July 19, 2019).
Taxpayers might need a tax transcript for many reasons, like applying for a mortgage or a student loan. The Let Us Help Youpage on IRS.gov will help taxpayers understand tax transcripts. This page has links to information that will help taxpayers learn about the different types of transcripts and the process of how to get one. … Continue reading IRS Tax Tip: Taxpayers who need to get a tax transcript should first visit IRS.gov
KPMG is hosting a free webcast, Understanding The Taxpayer First Act, on July 31, 2019, at 2.00 PM EDT. The description is as follows: Participants will learn about the important provisions and issues addressed in the recently enacted Taxpayer First Act including the New Independent Office of Appeals and IRS modernization and reorganization mandates. The … Continue reading KPMG: Understanding The Taxpayer First Act (Free Webcast)
The Taxpayer Advocate Service has released a "subway" style map of the US Tax system. The map's description is as follows: The map below illustrates, at a very high level, the stages of a taxpayer’s journey, from getting answers to tax law questions, all the way through audits, appeals, collection, and litigation. It shows the … Continue reading Taxpayer Advocate – The Taxpayer Roadmap 2019: An Illustration of the Modern US Tax System
In Kapp v. Commissioner, the Tax Court held a CPA liable for aiding and abetting understatement of tax on 3,218 tax returns of various taxpayers prepared by him for the tax years at issue. The opinion summary is as follows: P and his employees prepared thousands of tax returns and/or schedules for mariner taxpayers for … Continue reading Kapp v. Commissioner, T.C. Memo 2019-84 (July 9, 2019): CPA Held Liable for Aiding and Abetting Understatement of Tax; Penalties Imposed