Brager Tax Law Group posted that the IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM) 8.6.1.4, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone except under certain specific enumerated circumstances. Those circumstances are as follows: There are substantial…
Read more
Exelon Loses Over $1.6B Taxable Gain On Plant Sales
According to Law360, Exelon, the successor to Unicom Corp. and subsidiaries, had entered into a series of like-kind exchanges with unrelated tax-exempt public utilities after it sold its fossil fuel power plants in Northern Illinois for $4.8 billion in 1999. The exchanges involved sale and leaseback strategies by which the tax-exempt entities would receive a lump-sum payment…
Read more
Do you Have a Singapore Account? Singapore is Now Automatically Sharing Your Account Information!
On July 25, 2016 we posted Tax Havens Coming Clean and Becoming Transparent, where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory's general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine…
Read more
IRS Crack Down On Foreign Tax Credits For US Multinationals
The U.S. Department of the Treasury revealed on September 15, 2016 that it is drafting rules to curb US Multinationals from obtaining US foreign tax credits as a result of foreign government's audits resulting in foreign tax adjustments for US Multinationals. In Notice 2016-52, 2016-40 IRB, the IRS has announced that it intends to issue regs…
Read more
