Podcasts about irs office

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC's Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations. Together they walk through the core aspects of the PTEP regime, including PTEP accounting, increases and decreases to basis of stock and other property, foreign currency gain or loss, allocation of foreign tax credits, 'covered distributions', US consolidated group rules, and the anti-avoidance rule. See our PwC Tax Insight for more details. 

“If the decision-makers keep deciding that digital assets are just this fringe thing, there's going to be a missed opportunity”In this episode of Seize & Desist, our host, Aidan Larkin, explores tax compliance and enforcement in cryptocurrency with Miles Fuller, the director of government solutions at Taxbit, former senior counsel with the IRS Office of Chief Counsel and former Special Assistant United States Attorney.Miles shares his background in tax litigation with the IRS and provides insights into how Taxbit helps to trace criminal assets by combining on-chain and off-chain data to gain a comprehensive view of an individual's tax obligations.They also discuss the suitability of existing digital asset seizure legislation, the IRS' use of John Doe summons to obtain information from exchanges and the delicate balance between ensuring privacy in cryptocurrency transactions and preventing tax evasion before examining and speculating on the future of tax-related asset seizures.Timestamps00:00 - Special Announcement - Asset Reality's partnership with Taxbit03:00 - Miles' background with the IRS07:00 - Investigative tools and data aggregation in asset seizures10:30 - Tracing tools and address attribution in tax investigations11:30 - Integrating complex financial data for tax calculations13:00 - Streamlining financial investigations with crypto data tools16:00 - Challenges of detecting fraud in the virtual asset space21:00 - John Doe Summons in tax evasion investigations26:00 - Balancing privacy and compliance in blockchain transactions32:30 - Challenges of virtual asset seizures by governments41:00 - The future of tax compliance in the digital asset eraResources MentionedAsset Reality and Taxbit Partner to Enhance Digital Asset Seizure and ManagementDigital Asset Brokers: A Complete Guide to US Tax Compliance - Taxbit About our Guest:Miles Fuller is the Director of Government Solutions at Taxbit.As a former senior counsel with the IRS Office of Chief Counsel and former Special Assistant United States Attorney, Miles has a wealth of experience in tax-related asset seizures, having represented the IRS before the United States Tax Court, and has deep expertise in virtual asset tax and compliance issues, including regulatory guidance and policy development. Miles is also skilled in advanced investigation techniques for digital assets and has played a pivotal role in developing strategies to navigate the complexities of digital currency regulations.DisclaimerOur podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making decisions on the topics discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material.The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

When does a trust beneficiary's cooperation with a trustee to modify, reform, or decant a trust become a taxable gift by that trust beneficiary? In late 2023, the IRS Office of Chief Counsel answered that question in CCA202352018. In this episode, our guest Jenny Hill Bratt discusses the CCA and its impact on trust and estate practitioners and their clients.   About Our Guest:Jenny Hill Bratt is a partner in the San Diego (Del Mar) office of Sheppard Mullin.  Her practice is focused on US and international estate and income tax planning, trusts and estates administration, family and closely-held business planning and charitable planning and exempt organizations.Jenny is a fellow in the American College of Trust and Estate Counsel (ACTEC) and is certified as a specialist in estate planning, trust, and probate law by the State Bar of California Board of Legal Specialization. She served on the Executive Committee of the Trusts and Estates Section of the California Lawyers Association (TEXCOM), and was involved in the passing of the California Uniform Trust Decanting Act effective January 1, 2019. She is ranked by Chambers in Private Wealth Law.Jenny can be reached at jbratt@sheppardmullin.com or on LinkedIn.About Our Host: Matt Owens is a partner in the San Diego (Del Mar) office of Sheppard Mullin.  His practice is focused on trust, estate, and inheritance disputes.Matt is a certified specialist in estate planning, trust, and probate law by the State Bar of California Board of Legal Specialization. He is a member of the Executive Committee of the Trusts and Estates Section of the California Lawyers Association (TEXCOM), and served as Chair of the Executive Committee of the San Diego County Bar Association's Estate Planning, Trust, and Probate Law Section. He is ranked by Chambers in Private Wealth Disputes.Matt can be reached at mowens@sheppardmullin.com, on LinkedIn, or on X.Thank you for listening to Trust Me!Trust Me is Produced by Foley Marra StudiosEdited by Todd Gajdusek

It's already a busy start to the week with so many stories to know about so host Raheel Ramzanali is bringing on ABC13 reporter Chaz Miller to recap some of the big ones. The duo start things off with by talking about the economic impact of healthcare access disparities, then jump to rapid fire where hemp products might get regulation, and then they're ending with a story so wild that it can only happen in H-Town! Featured stories: How unequal access to healthcare is impacting our citizens and economy  It's about to get really hot again The trial of Brian Coulter  Lt. Gov. Dan Patrick takes aim at Delta-8 and Delta-9 products  Why this sailboat has been stranded on Galveston shores  Houston mom leaves kids alone for cruise  IRS event canceled after fight  Looking for more Houston news? Then sign up for our morning newsletter Hey Houston  Follow us on Instagram  @CityCastHouston Don't have social media? Then leave us a voicemail or text us at +1 713-489-6972 with your thoughts! Have feedback or a show idea? Let us know!  Interested in advertising with City Cast? Let's Talk! Learn more about your ad choices. Visit megaphone.fm/adchoices

State taxpayers have been sitting on a mountain of cryptocurrency assets for nearly a decade. According to one estimate, by the tax software and compliance firm Revenue Solutions Inc., 4.7 million California residents have stockpiled crypto assets valued at $56.2 billion, while 2.3 million New Yorkers are hoarding $27.7 billion in crypto. Are any of them paying capital gains taxes on the accumulated wealth tied up in Bitcoin, Ethereum, Tether and other digital tokens? And what about those investments in digital art, like Bored Ape Yacht Club non-fungible tokens? Tax compliance analysts believe barely a trickle of tax revenue linked to digital assets is flowing in the direction of state revenue departments. The reasons are varied. Revenue agencies and auditors just don't understand the crypto landscape. States and taxpayers alike lack full guidance from the federal government. Tracking digital asset transactions is difficult, and connecting them to specific taxpayers is even harder. Fran D'Antonio, solutions sales director at Revenue Solutions, and Miles Fuller, a 15-year veteran of the IRS Office of Chief Counsel who's now director of government solutions at digital tax compliance firm TaxBit, spoke with Bloomberg Tax senior reporter Michael J. Bologna about what they've seen in watching the crypto market closely for several years. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS closed more than 72,000 appeals last year and its Chief Counsel's Office received more than 65,000 cases. That's a lot of disputes. Safe to say they are about rules. Following rules. Not following rules. Questioning rules. Then, there are rules about rules that the IRS must follow.  The Administrative Procedure Act (APA) is such a beast. The APA places requirements on federal agencies when engaged in a “rule making” that has the force and effect of law. The APA has become a focal point in tax litigation, due in large part to the IRS's record of refusing to comply with the law's notice-and-comment mandate. In his article for the Journal on Emerging Issues in Litigation, our guest – Jeffrey S. Luechtefeld, shareholder at Chamberlain Hrdlicka – wrote about challenging the IRS, recent trends in tax litigation, and the future of APA challenges. And now, he's here on our humble podcast.  Jeff is a tax controversy and litigation attorney with a strong technical tax background and a deep understanding of the inner workings of the agency. Jeff advocates on behalf of clients in IRS examinations, appeals and litigation. Previously, he led the regional tax controversy practice for a Big Four accounting firm. He began his career with the IRS Office of Chief Counsel as a litigator, eventually becoming a Special Trial Attorney in the Large Business and International Division. Jeff received his JD from the University of Missouri, Columbia School of Law. I hope you enjoy the episode. If so, give us a rating!This podcast is the audio companion to the Journal on Emerging Issues in Litigation. The Journal is a collaborative project between HB Litigation Conferences, and the Fastcase legal research family, which includes Full Court Press, Law Street Media, and Docket Alarm -- all now part of vLex. If you have comments or wish to participate in one our projects please drop me a note at Editor@LitigationConferences.com. I'm often polite. Tom HagyLitigation Enthusiast andHost of the Emerging Litigation PodcastHome PageLinkedIn 

At the Annual Low Income Taxpayer Clinics Conference in Phoenix on December 7, 2022, I had the privilege of sitting down with Professor Keith Fogg, a mentor and colleague. Keith practiced at the IRS Office of Chief Counsel for over 30 years before he began an academic career in 2007 first running the Villanova Law Federal Tax Clinic and then running the Harvard Law Federal Tax Clinic from 2015 until his retirement in 2022. Additionally, Keith cofounded the Procedurally Taxing blog (for which I have written several articles) that he still helps run and his name is often associated with the American Bar Association Tax Section's Effectively Representing Your Client Before the IRS ("The Fogg Manual"), as he has edited the manual's 5th, 6th, and 7th editions (I had the privilege of authoring the worker classification chapter for the 8th edition).

Private letter rulings (PLRs) are one of many tools that tax and wealth planning professionals can employ to benefit their clients, but many professionals are unaware of the benefits of PLRs or don't know how to obtain PLRs.  Our guest, S. Eva Wolf, will provide us with guidance on the PLR process as it relates to common estate, gift and generation-skipping transfer tax issues.   About Our Guest:S. Eva Wolf's 15-year legal career has followed an atypical path; she has twice moved between private practice and government practice. Towards the beginning of her legal career, she worked as an Attorney (Estate Tax) in the IRS Estate & Gift Tax division, then returned to private practice where she advanced from associate to partner at Mitchell Silberberg & Knupp LLP, one of the oldest and most respected law firms in Los Angeles. Prior to joining the IRS Office of Associate Chief Counsel (PSI) as a Senior Attorney (Tax) in April 2020, Eva was a partner at Withers Bergman LLP, an award winning, global law firm. An Arizona native, Eva earned a B.A. in Sociology and a minor in Philosophy from Arizona State University and a J.D. from the University of Arizona. Eva also earned a Tax LL.M. from Loyola Law School, where she now teaches Estate & Gift Tax.  Eva also presented a webinar for CLA on the subject of this podcast episode, which can be found here:  Nuts & Bolts of Private Letter Rulings (inreachce.com)About Our Host: Host Anna Soliman is Trust Counsel and Managing Director for Fiduciary Trust International of California out of the Los Angeles Office. Prior to joining Fiduciary Trust International, Anna was an estate tax attorney for the Internal Revenue Service and also worked in private practice, specializing in estate planning and trust administration for ultrahigh net worth individuals.  She is also a TEXCOM member and is involved with the Fiduciary Income Tax Section of the American Bar Association. Thank you for listening to Trust Me!Trust Me is Produced by Foley Marra StudiosEdited by Todd Gajdusek

In what IRS officials call a groundbreaking event, the agency recently hosted a national virtual settlement event. In 59 meetings over four days, it settled 44 cases of less-than-rich taxpayers. To find out more, Federal Drive host Tom Temin talked with attorney Gretchen Altenburger, from the IRS Office of the Chief Counsel.

In S05E04, William Schmidt and Erin Collins discuss the benefit of working in the IRS Office of Chief Counsel, how things changed in moving to KPMG, some noteworthy cases, how being co-author of the IRS Practice and Procedure Deskbook benefitted her tax controversy practice, how her litigation background prepared her for being National Taxpayer Advocate (NTA), becoming the NTA at the beginning of the pandemic, what people should know when working with the Taxpayer Advocate Service, benefits of the ABA Section of Taxation, and tips for law students or young attorneys interested in tax.

From William Schmidt- I am going from being a Clinic Director for Low Income Taxpayer Clinics to working for the Kansas City branch of the IRS Office of Chief Counsel (Small Business/Self-Employed) as a Tax Attorney.  Today's episode is a short one as I make my farewells.   In September, I finished working for the Low Income Taxpayer Clinic and legal aid worlds, where I worked for 6.5 years. I worked for over 5 years for Kansas Legal Services and almost 1.5 years for Legal Aid of Western Missouri. I am going to miss working with others that advocate for those who truly need it. Both Kansas Legal Services and Legal Aid of Western Missouri are wonderful organizations that provide legal help to people in need. Through those organizations, I was able to provide tax, bankruptcy, consumer protection and other kinds of assistance through the years to low income taxpayers and other people in need. The Low Income Taxpayer Clinic community is a group that I will miss greatly. Gatherings from the local to the national level brought friendly, helpful people willing to talk tax and assist newcomers. I made several friends through the LITC, the ABA and in the IRS that were trying to connect taxpayers with the right assistance. I hope all of those organizations continue strong and you lend them support (if you're able) to bring help for those who need it.   I believe my 6.5 years within the Low Income Taxpayer Clinic world, writing regularly for Procedurally Taxing, podcasting for 180 episodes, presenting at conferences, teaching as an adjunct professor and more have led me to taking on this new experience. I look forward to working with others I know within the IRS and learning about IRS systems - I think this will be an interesting adventure!   The future of this podcast is a bit up in the air.  I have asked a couple people to take over, but in the meantime it will be going on hiatus.   Best wishes to you and thank you for listening!

The new Enterprise Digitalization and Case Management Office at the Internal Revenue Service, once just a procurement pilot, is incorporating innovative acquisition methods for technology and embracing customer experience principles to ramp up IT modernization efforts and reduce administrative burdens. Senior Advisor Mitch Winans, who helped stand up this office, discusses the progress made over the past nine months plus the partnership opportunities on the horizon.

A review of the week's major US international tax-related news. In this edition: US enacts $1.9 trillion COVID-19 stimulus legislation, including repeal of worldwide interest expense allocation election – IRS Office of Fraud Enforcement initiative to focus on virtual currency – IRS Advance Pricing and Mutual Agreement Program seeing questionable treatment of COVID-related costs – OECD official sees possibility for two simplification measures in BEPS 2.0 Pillar 2 agreement – Platform for Collaboration on Tax issues final version of Toolkit for Tax Treaty Negotiations.

Join Caroline Ciraolo of Kostelanetz & Fink, LLP as she discusses what is happening at IRS Office of Chief Counsel with our IRS Chief Counsel, Michael Desmond, from the New England IRS Representation Conference. Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/

Join Caroline Ciraolo of Kostelanetz & Fink, LLP as she discusses what is happening at IRS Office of Chief Counsel with our IRS Chief Counsel, Michael Desmond, from the New England IRS Representation Conference.     Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/

A look at Form 2848 processing with the CAF Unit.  Currently, there are processing delays.  Part of that is due to the COVID pandemic, but part of it is due to the time of year as there are some shutdowns as IRS employees use vacation time. But, wait – there’s more!  Sharyn Fisk, Director of the IRS Office of Professional Responsibility, submitted “Electronic Signature Options Will Simplify Third-Party Authorizations” on November 19, 2020, in CL-20-06.  The article details the plans for 2021 regarding what will be acceptable regarding electronic signatures with Form 2848 and Form 8821.  The IRS balances ease of access with concerns about fraud or identity theft.  Hopefully, more individuals can submit these forms to the IRS without having to worry about spreading the pandemic by being in the same room together. I hope you had a Happy Thanksgiving and will have a safe holiday season!

She may not be known to the general public, but this IRS executive helps tax preparers and the tax community generally navigate the system and also maintain professional standards. Especially important in a year like the IRS and the nation is going through. The director of the IRS Office of Professional Responsibility, Sharyn Fisk, joined the Federal Drive with Tom Temin.

Living and working in Yuma; As a DEA Agent in Yuma AZ, Episode 7; An Explosion Inside the IRS Office, Leaks & Corruption in Law Enforcement, and I'm Not Stopping. These stories are based on his life presented in the book Fighting My Greatest Enemy, Myself. His book and our earlier book; Path of the Devil, Camino del Diablo are available on Amazon. larryrayhardin.com

Agencies have seen IT investments pay dividends during the coronavirus pandemic putting them in a better position to maximize telework and ensure continuity of operations. Some agencies are taking the next step to robotic process automation fielding bots to help employees keep up with their workload. For more on how RPA has helped agencies keep pace during the pandemic. Federal News Network’s Jory Heckman spoke with the Patent and Trademark Office’s acting director of the Office of Organizational Policy and Governance Rajeev Dolas. He also spoke with Mitch Winans, special assistant with the IRS’ Office of the Chief Procurement Officer.

This episode focuses on the big picture view of “the new normal for taxes” since there have been several changes connected to the coronavirus pandemic.  Topics discussed include missed opportunities and new opportunities related to the ABA May Tax Meeting, Tax Court, free webinars, Virtual Settlement Days, and more.   Some tips: If there were issues with the economic impact payment, some of the potential assistance I know about are the phone number 1-800-919-9835 or using IRS form 3911. Otherwise, the main advice I have is to file a 2019 tax return separately if you need to show on record that you are no longer with the spouse from a joint return so that you can potentially receive the payment as a refund on the 2020 tax return.   The University of San Diego Law School has for free virtually their 5th Annual Tax Controversy Institute on July 17 looking at tax controversy work during COVID-19, the IRS Office of Professional Responsibility, and IRS Fraud Enforcement and Criminal Investigations. https://www.eventbrite.com/e/5th-annual-usd-school-of-law-rjs-law-tax-controversy-institute-tickets-93194377893   Kostelanetz and Fink is holding the 12th Annual NYU Tax Controversy Forum for free virtually on June 18 and 19. By the time this airs, those dates may have passed, but they are available through CPAcademy, which will be rebroadcasting those webinars during the summer.  The webinars will have updates from the heads of several departments at the IRS such as the new Taxpayer Advocate Erin Collins and new head of the Independent Office of Appeals Andy Keyso.  They will also have presentations on penalties, fraud, Tax Collections, and enforcement. https://kflawtaxforum.com/agenda/   ABA Virtual May Tax Meeting is June 10 through July 30. 19 webinars over 6 weeks covering ethics, Tax Court, international tax, corporate tax (19 or so committees).  Rates range from free to $500 for the entire series, depending on your category. June 10: Tax Bridge to Practice1:00pm - 4:05pm June 11: Corporate Tax/Affiliated & Related Corporations1:00pm - 2:35pm June 17: Tax Accounting1:00pm - 3:00pm June 18: Closely Held Businesses1:00pm - 2:45pm June 24: S Corporations1:00 - 4:00pm June 25: State & Local Taxes1:00pm - 3:00pm July 1: International Day 112:00pm - 1:30pm July 2: International Day 21:00pm - 4:00pm July 8: Real Estate & Partnerships & LLCs1:00pm - 4:00pm July 9: Estate and Gift Taxes1:00pm - 4:00pm July 14: Civil & Criminal Tax Penalties1:00pm - 4:00pm July 15: Exempt Organizations1:00pm - 4:00pm July 16: Financial Institutions & Products1:00pm - 3:00pm July 21: Sales, Exchanges and Basis/Capital Recovery and Leasing1:00pm - 4:00pm July 22: Court Procedure & Practice1:00pm - 3:00pm July 23: Investment Management1:00pm - 4:00pm July 28: Employee Benefits1:00pm - 4:00pm July 29: Administrative Practice1:00pm - 3:00pm July 30: Standards of Tax Practice1:00pm - 3:00pm *All sessions are live in Eastern Standard Time  

Lynn Nichols Federal Tax Update Podcast May, 03 2019, Episode 39 Listen as Lynn Nichols provides commentary on 4 Items pertaining to current developments in U.S. tax law. IRS Official: Good Recordkeeping Protects Against Bad Clients Documentation can save practitioners whose clients ignore their advice and apply for tax-exempt status, even when they know they don’t qualify, according to an IRS Office of Professional Responsibility official. [Tax Notes Today; 4/29/2019, Article by Kristen Parillo]   IRS Grants Tax Exemption to Massachusetts-Based Satanic Temple   The Satanic Temple, a self-described nontheistic religious satanic organization based in Massachusetts, has been recognized as a church and granted tax-exempt status by the IRS. [Tax Notes Today; 4/29/2019, Article by Paige Jones]   Tenth Circuit Affirms Liability for Penalty for Overvaluing Easement The Tenth Circuit affirmed a Tax Court decision that held a couple liable for a gross valuation misstatement penalty for overstating the value of a conservation easement donation and that held they weren’t entitled to deductions under section 1341 for the repayment of proceeds they received for the sale of state tax credits. [John L. Roth; CA 10, No. 18-9006, 4/29/2019]   Collection Action Sustained Against Food, Wine Festival Operator The Tax Court held that an IRS settlement officer didn’t abuse her discretion in rejecting a hospitality management company’s proposed installment agreement and sustaining the proposed collection action for $1.4 million in tax liabilities, finding that the company wasn’t in compliance with its current employment tax deposit obligations. [Coastal Luxury Management Inc.; No. 24206-16L; T.C. Memo. 2019-43, 4/29/2019] Extended notes coming soon.

Lynn Nichols Federal Tax Update Podcast March 19, 2018, edition   Listen as Lynn Nichols provides commentary on 10 Items pertaining to current developments in U.S. tax law. This week’s topics include: Attractiveness of S Corporations After 2017 Larry Crumbley and James R. Hasselback discuss how the Tax Cuts and Jobs Act made significant changes that apply to S corporations, and they compare advantages and disadvantages of S corporation and C corporation status. [Tax Notes Today, 3/12/2018, Article]  Individual Can Amend Complaint to Make False Information Returns ClaimA U.S. district court granted a pro se individual leave to amend her complaint against Amazon Services LLC that alleged the company improperly reported income for her to the IRS that resulted in a tax liability; she now may make a cognizable claim under section 7434 that Amazon willfully filed false information returns for her. Employer-Provided Tax Prep Services Are Includable in Employee IncomeIn a legal memorandum, the IRS ruled that tax preparation services provided by a U.S. corporation for the benefit of its employees working in foreign countries are includable in the gross income of those employees at the fair market value of the services. [ILM 201810007; 11/28/2017, released 3/9/2018]  Payments to Property Owners Not Reportable IncomeThe IRS ruled that subsidiaries that are required by a state to make payments to, or incur costs on behalf of, eligible property owners don’t have to provide information returns for those costs or payments; the IRS declined to rule on the effect of future compensatory payments to additional property owners because those payments are the subject of current litigation. [LTR 201810004; 12/8/2017, released 3/9/2018]  JCT Reviews Federal Tax Provisions That Expired in 2017The Joint Committee on Taxation, in a report (JCX-5-18) prepared for a March 14 House Ways and Means Tax Policy Subcommittee hearing, listed federal tax provisions that expired in 2017 and staff revenue estimates of making these provisions permanent. [ JCX-5-18; 3/14/2018] Decisions to Revoke S Corp Elections Not Just About the RatesSubchapter S corporations that may be lured by lower rates to convert to C corporation status might face some unanticipated and undesirable consequences if they overlook broader tax implications and longer-term strategic considerations. [Tax Notes Today; 3/14/2018; Article by Emily L. Foster] IRS Ending Offshore Voluntary Disclosure ProgramThe IRS has announced (IR-2018-52) that it will begin to ramp down and end the 2014 Offshore Voluntary Disclosure Program on September 28, 2018, urging U.S. taxpayers with undisclosed foreign financial assets to use the program before it closes. [IR-2018-52; 3/13/2018]  New LB&I Compliance Campaigns Include 3 Partnership IssuesThe IRS Large Business and International Division has announced five more campaigns, including three dealing with partnership issues. [Tax Notes Today; 3/14/2018, Article by Stephanie Cumings] LB&I Plans Exams of Spinoff Costs Without Explicit RulesThe IRS intends to enforce the requirement that taxpayers capitalize facilitative costs for tax-free distributions in spinoff transactions despite a dearth of guidance on how that should be done. [Tax Notes Today; 3/15/2918, Article by Emily Foster]   IRS Curbs Benefit Plan With No Meaningful BenefitsEmployees who don’t receive benefits under a floor-offset plan, while the highly paid executives do, can’t be counted for purposes of the plan’s minimum participation requirement, according to the IRS Office of Chief Counsel. [Tax Notes Today; 3/15/2018, Article by Stephanie Cumings] Tax Court Holds Short Sale, Debt Cancellation Was Single TransactionThe Tax Court, declining to impose an accuracy-related penalty, held that a couple’s short sale of a townhouse and resulting debt forgiveness on their mortgage was a single transaction for which they recognized neither a gain nor loss. [Simonsen, Karl F. et ux. v. Commissioner; No. 29698-14; 150 T.C. No. 8, 3/14/2018]

In January 2017, the IRS Office of Chief Counsel issued a memorandum clarifying the tax treatment of certain types of fixed indemnity plans offered by employers. Since the memorandum was released, several fixed indemnity plan insurance carriers have pushed back, stating that the interpretation of the IRS memo was too broad and should not affect the taxation of such plans. Listen in to learn how and if this affects various types of hospital and critical care reimbursement plans, cancer and accident plans, and other similar type lump sum reimbursement arrangements.

Today we’re talking about the IRS Office of Appeals.We’ve got some information you need to know.Many tax disputes are not resolved in favor of the taxpayer. Many times, the IRS is wrong in their conclusions. There are remedies if you feel you have a strong case and can support that case with the IRS.The IRS Office of Appeals was formed in 1927. Their mission is, “To resolve tax controversies, without litigation, on a basis which is fair and impartial to both the government and the taxpayer in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the service.”Tax controversies can involve proposed tax assessments, tax collection, or other IRS actions. Once the IRS issues a final notice, taxpayers can generally seek a remedy from the courts. However, the appeals process is less formal and less costly than court proceedings and is not subject to judicial rules of evidence or procedure. Historically, it has been able to settle the majority of the cases that have come before it. In addition, taxpayers do not give up judicial review by coming to the IRS Office of Appeals and can still go to court.One very important aspect of the Office of Appeals is that the office is independent from IRS compliance functions and this is critical for it to accomplish its mission: to resolve disputes effectively.“The office is independent fromIRS compliance functions. ” How do you know if the IRS Office of Appeals is the right place for you? To qualify for appeals, ALL of the following items must apply:You received a letter from the IRS explaining your right to appeal the IRS’s decision.You do not agree with the IRS’s decision.You are not signing an agreement form sent to you.If all of the above are true, then you may be ready to request a conference or hearing.This course of action is not for you if ANY of the following apply:The correspondence you received from the IRS was a bill and there was no mention of appeals.You did not provide all information to support your position to the examiner during the audit.Your only concern is that you cannot afford to pay the amount you owe.If you cannot qualify for the IRS Office of Appeals, you should talk again with the person at the IRS you have been dealing with or contact taxpayer services for assistance. You can also contact the taxpayer advocate service if you feel your taxpayer rights have been violated.If you have tax problems, you should protect yourself by hiring a qualified tax problem specialist. We have experience in strategies in negotiating with the IRS to get you the lowest amount that you have to pay.If you have a tax problem or know someone with a tax problem, please share this video or contact me by giving me a call or sending me an email. I look forward to hearing from you soon.

In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, begins with the general news, where he provides a brief look at the presidential primary races. Then, he reviews a recently released memo from the IRS Office of Chief Counsel, which provides additional indications as to how the IRS views certain carve-out guarantees of otherwise nonrecourse partnership loans. In the low-income housing tax credit section, he outlines the bill that the Senate Appropriations Committee last week approved regarding funding for transportation and HUD in fiscal year 2017. After that, he discusses how two Louisiana state bills could change the way property taxes for low-income housing tax credit developments are calculated. In new markets tax credit news, he talks about the CDFI Fund's exciting announcement that $7 billion of new markets tax credit allocation authority will be awarded later this year. In the historic tax credit section, he discusses why efforts to extend the state historic tax credit in Alabama may have hit a wall, despite being passed in one chamber of the legislature by a vote of 91-4. And he closes out with renewable energy tax credit news, where he talks about how certain technologies "orphaned" by last year's energy investment tax credit extension might find another legislative vehicle before the end of the year.

In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, begins with the general news, where he provides a brief look at the presidential primary races. Then, he reviews a recently released memo from the IRS Office of Chief Counsel, which provides additional indications as to how the IRS views certain carve-out guarantees of otherwise nonrecourse partnership loans. In the low-income housing tax credit section, he outlines the bill that the Senate Appropriations Committee last week approved regarding funding for transportation and HUD in fiscal year 2017. After that, he discusses how two Louisiana state bills could change the way property taxes for low-income housing tax credit developments are calculated. In new markets tax credit news, he talks about the CDFI Fund's exciting announcement that $7 billion of new markets tax credit allocation authority will be awarded later this year. In the historic tax credit section, he discusses why efforts to extend the state historic tax credit in Alabama may have hit a wall, despite being passed in one chamber of the legislature by a vote of 91-4. And he closes out with renewable energy tax credit news, where he talks about how certain technologies “orphaned” by last year's energy investment tax credit extension might find another legislative vehicle before the end of the year.

How can public agencies at the federal, state and local levels use analytics — including test and learn strategies — to tackle their toughest challenges? We get insights from Dean Silverman, the founder and former head of the IRS Office of Compliance Analytics (OCA), which launched in 2011. Reporting directly to the IRS commissioner, the OCA’s mission […] The post Using analytics to tackle tough agency challenges: An interview with Dean Silverman, former head of the IRS Office of Compliance Analytics – Episode #84 appeared first on Gov Innovator podcast.