Trustees May Be a Target of IRS Audits
Nixon Peabody LLP
A recent article in The Bond Buyer reported that the IRS will begin an audit program sweep this summer to examine whether the failure by trustees to roll escrow funds held under refunding escrows for tax-exempt issues into zero-interest rate State and Local Government Series (SLGS) securities may have resulted in issuer arbitrage violations.
Corporate Tax Shelters--What Will Be the Impact of the New Regulations on U.S. Multinational Corporations?
Carol P. Tello of Buchanan Ingersoll & Rooney PC
Introduction In late February of this year, the Internal Revenue Service issued three sets of temporary and propo.
Christmas in May: Tax Court Judge Lynn W. Davis' Extraordinary Decision
Maxwell A. Miller of Parsons Behle & Latimer
Usually with indignant disbelief, my taxpayer clients often lecture me that constitutional safeguards routinely extended to others, like accused felons and ?garden variety? plaintiffs, find no counterparts in the tax world. The taxpayers? point is that the state must prove criminal guilt ?beyond a reasonable doubt,? while the reverse applies to taxpayers, who must prove the taxing authorities? presumptively correct assessments are wrong.
Beyond the Legend: The Impact of New Circular 230
Terrence G. Perris of Squire, Sanders & Dempsey L.L.P.
By now, corporate taxpayers will have noticed a change in much of the written tax advice they have received from their outside tax advisers after June 20, 2005. This change is the immediate result of new regulations the U.S. Treasury has issued to regulate advisers who provide U.S. federal tax advice. The Treasury issued these regulations (which are referred to as "Circular 230") under its statutory authority to regulate those who are authorized to practice before the Treasury and the Internal Revenue Service.
Social Security Numbers for Foreign Nationals
Paul, Hastings, Janofsky & Walker LLP
The Social Security Administration has determined recently that it will no longer issue a Social Securit.
Your Rights When You Owe the IRS
Robert S. Schriebman of Law Office of Robert S. Schriebman
In July, 1998, President Clinton signed the IRS Restructuring and Reform Bill of 1998. This legislation is the beg.
IRS Announces 2001 Cost of Living Adjustments for Benefit Plans
Faegre & Benson LLP
This article addresses the 2001 cost of living adjustments for benefit plans.
Tax Litigation Primer
Maxwell A. Miller of Parsons Behle & Latimer
Tax litigation is not for the faint of heart. Almost no one wins everything requested, and certainly not every time. Nonetheless, the taxpayers with whom I deal invariably tell me that in the long run taking an aggressive posture saves their companies tax dollars that they should not have to pay.
Change in Ohio Taxation of Electing Small Business Trusts
Brian W. Fitzsimons of Arter & Hadden LLP
This article details some recent business tax changes in Ohio.
IRS Announces New Audit Program
Benjamin I. Delancy of Thelen LLP
This article discusses the creation of a new IRS tax audit task force.
Civil Controversies: Tax Court Stipulations
Martin Brown & Sullivan
For fair and reasonably efficient resolution of federal tax disputes, the United States Tax Court is a remar.
Challenge your property tax assessment
Brian S. Jablon of Saltzman & Jablon, LLC
MANY PAY MUCH MORE THAN THEY SHOULD Are your property taxes higher than .
Can the IRS take Your Home? Your Business?
Robert S. Schriebman of Law Office of Robert S. Schriebman
Can the IRS take your home? Your business? The answer to these questions is "yes". If you owe the IRS .
Discriminatory Retirement Plan Amendments Briefs. Vol. 13, No. 1
Nixon Peabody LLP
This article discusses the IRS's discriminatory retirement plan amendments and explains IRS. Rev. Rul. 99-51.
IRS Change Encourages
Leonard M. Gold of Lakin, Solomon & Gold, P.A.
A common scenario faced by tax and insolvency attorneys is the client who has incurred substantial tax liability to.
You Don't Have to use the Postal Service to Send Mail to IRS -- But Watch Out
Bardin Levavy of Meislik & Meislik
Until this year, if you wanted to comply with the "timely mailing as timely .
New Rules for Privatization
William F. O'Brien of Thelen LLP
This article discusses the U.S. Internal Revenue Service issuance of important new rules affecting tax-exempt bondsÃÂrules that will accelerate the trend toward privatization of public facilities.
Educational Institutions Law Alert: IRS Audit Agenda Targets 403(b) Plans
Saul Ewing LLP
The Internal Revenue Service has recently announced that it will continue to commit substantial resources toward th.
Summary of Important New Tax Legislation
Frederick W. Richards, P.A.
As I am sure you are aware, a number of significant changes have been made to the tax laws in recent years.
Individual Tax ID Numbers:
Law Offices of Richard A. Gump, Jr.
The Internal Revenue Service is implementing new procedures to provide individual taxpayer identification numbers .
Taxpayer Bill of Rights--The Sequel
Fargarson & Brooke
In 1996, Congress revisited the Taxpayer Bill of Rights (T1), originally passed in 1988. The new law, .
IRS Targets Withholding on Employee Stock Purchase Plan Transactions
Cooley Godward Kronish LLP
This alert addresses the IRS's move to aggressively assert that stock issued pursuant to Employee Stock Purchase Plans ("ESPPs") is subject not only to federal income tax withholding but also FICA and FUTA withholding requirements.