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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IRS awash in whistleblowers after $104M payout!
Whistleblower Bradley Birkenfeld, whose $104 million reward from the U.S. Internal Revenue Service set a record three weeks ago, has helped set off a rush of would-be imitators hoping to cash in on a government program to catch tax cheats. Birkenfeld, now living in New Hampshire, helped lead the IRS to collect hundreds of millions…
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Government May Attach Lien to Half-Interest in Property Held in Tenacy by the Entirety.
The U.S. Court of Appeals for the Sixth Circuit, on Aug. 6, affirmed a district court's judgment that concluded that the government's federal tax lien that arises by operation of law in “all property and rights to property” of a delinquent taxpayer (26 U.S.C. 6321) attaches to the rights of that taxpayer in property held…
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