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Yearly Archives: 2018

IRS Cost-Sharing Regulations Revived By Appeals Court

According to Law360, the Ninth Circuit on Tuesday reversed a decision by the U.S. Tax Court that invalidated an Internal Revenue Service cost-sharing regulation in a dispute with an Intel Corp. subsidiary, saying the revenue agency did not exceed its authority in promulgating the rule. In a 2-1 decision, the appeals court said the IRS is…
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Understanding IRS Tax Audits – Part I

Careful advance preparation can help reduce the scope of a tax audit or examination and can lead to a more favorable outcome. Although a thorough understanding of the underlying facts and applicable law is a must, understanding IRS procedures is critical to preserving a taxpayer’s rights. We summarize below and in Parts II & III,…
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IRS Added 6 New Compliance Campaigns Audit Strategies for LB&I

On May 24, 2018 we posted IRS Has 6 New Compliance Campaigns Audit Strategies for LB&I where we discussed that on may 21, 2018 the irs announced the identification of 6 large business and international compliance campaigns. Now on July 2, 2018, the IRS announced that it has identified and selected the following five additional issues:  Restoration of sequestered…
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IRS Spent $380 Million on FATCA but took NO Action Against Offshore Tax Dodgers?

 What Happened To The FATCA  Wrecking Ball?   Despite pouring nearly $380 million into a new tax enforcement initiative, the U.S. government took “limited or no action’’ in its campaign to battle secretive offshore holdings used to dodge taxes, according to a new report by a federal watchdog. The Treasury Inspector General for Tax Administration…
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