Taxpayers Permitted to Request Guidance on Corporate Business Purpose and Device Requirements On August 26, 2016, the Internal Revenue Service (IRS) issued Revenue Procedure
2016-45, stating that it is willing to provide private letter rulings to taxpayers pertaining to the corporate business purpose and device requirements that are required for a spinoff to be tax-free.
2015-41) on requesting and obtaining an advance pricing agreement (APA), modifying somewhat its proposed revenue procedure
published in Notice 2013-79.
Recently, the IRS issued Revenue Procedure
2013-34 to provide guidance on innocent spouse equitable relief (IRB 2013-43).
The revenue procedure
also allows small businesses to make certain accounting method changes on a cutoff basis, that is, with a Sec.
Commissioner, the Internal Revenue Service has issued much-anticipated guidance meant to provide "predictability" to investors in historic rehabilitation tax credit projects in the form of Revenue Procedure
This revenue procedure
, generally, is taxpayer favorable and should likely ease compliance burdens, especially for small business, through simplified procedures.
The statistical sampling approach must be consistent with the guidance provided in Revenue Procedure
2011-38 amends Revenue Procedure
2008-24 regarding partial exchanges of cash value of annuities.
At long last, the IRS has issued a Revenue Procedure
which provides a "safe harbor" to taxpayers seeking to perform a [Section] 1031 exchange with real property held primarily for investment but partially used by the taxpayer for personal enjoyment.
To avoid this adverse result, the IRS issued a revenue procedure
stating that CRTs created on or after June 28, 2005, will not be disqualified if the surviving spouse waives the right of election.
Contemporaneous with issuance of the disclosure regulations, the IRS issued a revenue procedure
Internal Revenue Service's Revenue Procedure
98-25, which imposes certain long-term data retention requirements on corporate taxpayers.