FDIC Board in Split Vote Proposes Permanent Securitizations Safe Harbor Rule

The Federal Deposit Insurance Corporation’s board of directors May 11 approved a notice of proposed rulemaking on safe harbor conditions for securities originated by failed banks…

Bank Profits Reach Two-Year High, but Failures Expected to Peak in 2010

Banks’ aggregate profit reached a two-year high of $18 billion in the first quarter of 2010, but the number of troubled banks also rose to 775, the highest since June 30, 1993, according to…

Chinese Bar Against PCAOB Inspections Poses Risk for U.S. Investors, Acting Chairman Says

Prohibitions against Public Company Accounting Oversight Board inspections of the work of auditing firms in China raise the possibility that, as more Chinese companies operate and file…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

Taxpayers Offering to Participate in IRS Transfer Pricing Initiative, IRS Official Says

Taxpayers have been stepping forward to participate in the Internal Revenue Service’s new transfer pricing initiative within the Large and…

ANALYSIS: HIRE Act Change Suspends Limitations When Taxpayers Fail to Report International Transactions

A recent amendment to Section 6501(c)(8) has the sweeping effect of keeping the statute of limitations open for all issues on a taxpayer’s return if it fails to report international transactions on…

Congress Aware of Issues That Surround Statute of Limitations Provision, Aide Says

Members of Congress are aware of the issues surrounding a controversial provision on the statute of limitations in legislation to require broad new reporting by foreign banks, a lawyer on…

New Law Could Prevent Closing out Reserves for Some Tax Positions, Practitioners Fear

A new tax law seemingly intended to apply only to the statute of limitations for assessments on foreign information filed with the Internal Revenue Service could force financial statement preparers…

IRS Will Oppose Privilege Claims Where Accountant Is Hired by Lawyer, Official Says

The government is likely to oppose claims of privilege for accountants who have been hired by lawyers representing clients in tax cases, a senior Internal Revenue Service criminal attorney said May 6…

IRS Seeking Targeted Information Regarding Uncertain Tax Positions, Sullivan & Cromwell Says

The Internal Revenue Service appears to be requiring taxpayers to provide significantly pinpointed information describing their uncertain tax positions under a proposal mandating disclosure of…

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