In PLR 201240018the IRS has ruled that a life insurance company that offers nonqualified annuity contracts invested in indexed-linked options, and not the contract owners, owns the assets it held in support of its contractual obligations with respect to these options. Taxpayer possesses the following ownership attributes in the assets it holds to support the…
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Attention All Whistle Blowers, The IRS Needs $$$!
It is no secret that the IRS needs money. It’s also no secret that the IRS is paying for information. The IRS’s Whistleblower Office has released its fiscal year 2010 annual report to Congress, and it’s an eye opener. How big is this topic? The entire Swiss banking industry was brought to its knees because…
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Extraterritorial Income Exclusion Does Not Apply to Reduce a CFCs' Subpart F Income
In Chief Counsel Advice 201240019, IRS has determined that former IRC Sec. 114's extraterritorial income (ETI) exclusion doesn't apply for purposes of determining the amount of subpart F income that a taxpayer/CFC shareholder was required to include under Code Sec. 951(a)(1)(A)(i). The applicability of the ETI provisions turned on certain provisions within subchapter N which…
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IRS Clarifies Temporary ITIN Application Requirements for Noncitizens with Tax Extensions and Many Foreign Students
Effective Oct. 2, 2012, the IRS implemented two separate clarifying changes to its temporary procedures for issuing Individual Taxpayer Identification Numbers (ITINs). First, the IRS will allow individuals studying in the United States under the Student Exchange Visitors Program (SEVP) to get ITINs under a streamlined procedure. SEVP participants already provide documentation to the Department…
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