Four days after we posted "2014 LB&I Information Document Request (IDR) Enforcement Process - Ready or Not?," the IRS postponed the effective date to March 3, 2014.The IRS Large Business and International Division announced that it will be extending the effective date of the enforcement procedures as outlined in the Nov. 4, 2013 LB&I Directive…
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FATCA Implementation Unimpeded by Republicans!
According to Reuters, A senior U.S. Treasury Department official said on January 22, 2014 that Republican Party opposition to a new law meant to fight offshore tax dodging by Americans will not impede the Obama administration's efforts to implement it worldwide. The Republican National Committee (RNC) on January 24, 2014 called for the repeal of…
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IRS Determines That Debt Secured By Wholely Owned Dissregarded Entity Qualifies For Income Exclusion on Workout.
The IRS has issue Revenue Procedure 2014-20 which provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of §…
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2014 LB&I Information Document Request (IDR) Enforcement Process – Ready or Not?
We had previous posted Are Your Ready For The IRS' New Rigid IDR Enforcement Procedures? regarding that on June 18, 2013, the Acting LB&I Commissioner issued a directive (LB&I Control No: LB&I-04-0613-004) to LB&I employees announcing that for all IDRs issued after June 30, 2013: The examiner must identify and state the issue that has led…
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