Carried Interest Tax Increase, S Corporation Curbs Softened in New Tax Extenders Proposal by Senate Finance Panel Chair Baucus

Senate Finance Committee Chairman Max Baucus (D-Mont.) June 16 introduced a new substitute amendment (S. Amdt. 4369) to the tax extenders bill (H.R. 4213) that would…

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…

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…

Pace of Change in Cross-Border Transparency Initiatives Increasing, IRS Official Says

The pace of change in the new world of increased transparency and information exchange has “accelerated on all fronts,” Internal Revenue Service Deputy Associate Chief Counsel (International) Theodore…

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…

Tax Attorneys Criticize Potential Prosecutions of Some Who Disclosed Offshore Assets

A group of criminal tax attorneys is criticizing the Internal Revenue Service for potentially bringing criminal charges against taxpayers who tried to tell the government about offshore assets under…

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…

International Tax Law Changes Should Be Left for Broad Reform, Business Groups Say

Fifteen major organizations participating in the Promote America’s Competitive Edge (PACE) Coalition called on Congress in an April 26 letter to move cautiously in modifying international tax provisions in…

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