American Institute of Certified Public Accountants Offers Comments to Treasury, IRS on Foreign Bank Account Report Guidance

The American Institute of Certified Public Accountants May 17 unveiled comments on requirements for taxpayers required to file the Report of Foreign Bank Account (FBAR) …

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 Unveils Draft Schedule, Instructions for Reporting Uncertain Tax Positions

The Internal Revenue Service April 19 unveiled the eagerly awaited draft schedule and instructions that taxpayers would use to report their uncertain tax positions under…

Seventh Circuit Overturns Tax Court Ruling on Exempt Interest Expenses of Qualified Subchapter S Subsidiary Bank

The U.S. Court of Appeals for the Seventh Circuit March 17 found that shareholders in an S corporation—which is the sole shareholder of a tax code Section 1361(b)(3)(B) qualified…

U.S.-U.K. Treaty Does Not Exempt U.K. Foundation from U.S.-Source Dividends Tax

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released March 12, said the U.S.-U.K. income tax treaty does not exempt a U.K.-based private foundation from…

Rep. Levin Assumes Acting Chairmanship of House Tax Committee over Rep. Stark

Rep. Sander Levin (D-Mich.) March 4 assumed the acting chairmanship of the House Ways and Means Committee a day after Rep. Charles Rangel (D-N.Y.) stepped…

Government Provides Targeted Guidance, Proposes Rules on Report on Foreign Bank Account Requirements

IRS unveils targeted guidance that practitioners say will provide significant relief for taxpayers required to file the Report of Foreign Bank Account, on the heels of…