Newly Codified Economic Substance Doctrine Could Mean More IRS Challenges, Practitioners Say

The newly codified economic substance doctrine may clear the way for Internal Revenue Service challenges to a broader range of transactions than before, tax practitioners said May 20…

Business Groups Oppose Tax Extenders Bill, Put Pressure on Democrats on Eve of House Vote

Business organizations May 24 lashed out against congressional Democrats’ tax extenders and jobs bill (H.R. 4213) set for House floor consideration, saying that its permanent tax increases on…

IRS, Treasury Working on Consolidated Groups Guidance Under Net Operating Loss Carryback

The Internal Revenue Service and Treasury Department soon will issue guidance to address issues for consolidated groups raised by the recently enacted five-year net operating loss carryback…

Manufacturing Deduction Impacted in Years New Net Operating Loss Carryback Used, IRS Officials Say

Taxpayers who claim the newly enacted five-year net operating loss carryback should be careful about the impact if they carry back their losses to any year in which they also claimed the manufacturing deduction under…

BNA INSIGHTS: Tax-Based Leasing, Tax Credits, and Economic Substance

Leasing has traditionally been a way for developers and other users of equipment to indirectly access tax credits and other government incentives for capital investment (such as accelerated depreciation) when…

IRS Uncertain Positions Documents Answer Some Questions, Leave Others, Practitioners Say

The draft schedule and instructions that taxpayers would use to report uncertain tax positions, unveiled by the Internal Revenue Service April 19, are administratively helpful and well…

IRS Corporate Audits Declining, Research Group Says; Agency Disagrees with Analysis

The Internal Revenue Service’s audit efforts aimed at the nation’s largest corporate taxpayers have declined since 2005 and are now “at an all-time low,” according to…

Obama Signs Measure Creating $13 Billion in Tax Breaks for Businesses Hiring Workers

President Obama signed the HIRE Act (Pub. L. No. 111-92) into law March 18, creating tax breaks for businesses hiring new workers and extending higher expensing limits for small businesses that…

ANALYSIS: Who Needs ‘Customers’? The Real Import (or Export) of IRS Announcement 2010-9 on ‘Uncertain Tax Positions’

If anything explodes the fiction that the U.S. Internal Revenue Service and the taxpayer—particularly the corporate taxpayer—are in a constructive partnership…

Proposed Payment Card Reporting Rules Would Put U.S. Payers at Competitive Disadvantage, Witnesses Tell IRS

Witnesses at a March 15 Internal Revenue Service hearing on payments made to settle payment card and third-party network transactions focused on the foreign reporting requirements of …

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