IRS Counsel Says Information Reporting Regimes Will Alter Tax Administration

The Internal Revenue Service’s “enhanced information reporting” initiatives coupled with the onset of tax return preparer regulations will transform aspects of tax administration…

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 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…

Guidance on Definitions, Scope, Carveouts Initial Focus under New Foreign Account Tax Compliance Act, IRS Official Says

Guidance on broad new requirements that foreign financial institutions report accounts with U.S.-owned assets to U.S. tax authorities is likely to focus first on carveouts and…

Recent IRS Moves on Uncertain Tax Positions, Foreign Bank Reporting Seen Having Transfer Pricing Implications

Recent actions by the Internal Revenue Service on uncertain tax positions and by Congress on reporting and disclosure requirements for foreign banks have implications for transfer pricing, KPMG LLP practitioners…

Foreign Accounting Tax Compliance Act’s 2013 Effective Date Due to Consideration of Foreign Law, JCT Staffer Says

The application of foreign law was a consideration when drafting the Foreign Accounting Tax Compliance Act, which contains a reasonable period of time for compliance on the part of…

IRS International Enforcement Extends to Many Cases Where No Tax Due, Practitioner Cautions

Taxpayers should be aware that the Internal Revenue Service’s intense focus on international tax compliance applies in many cases where tax is not due, a Sullivan & Worcester practitioner said April 28…

IRS Focused on Timelines, Burdens in Implementing Foreign Accounting Tax Compliance Act Provisions, Top Official Says

Internal Revenue Service Associate Chief Counsel (International) Steven Musher April 26 said the agency remains focused on timelines and on imposing the least possible burden on taxpayers as it works to implement comprehensive…

Uncertain Tax Positions Reporting Not Road Map for Adjustments, IRS Chief Counsel Says

Internal Revenue Service Chief Counsel William Wilkins April 23 reiterated that the agency does not plan to use the information it gets from taxpayers on uncertain tax positions as a road map for…

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