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IRS Insights

Perspectives

IRS Insights

A closer look.

IRS Insights, published by the Deloitte Tax LLP Tax Controversy Services group, provides a compact, reader-friendly perspective on the latest practices and procedures coming out of the Internal Revenue Service (IRS), as well as the potential impact of changes on taxpayers.

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Recent editions appear below; for older issues, please email a request to ustaxnews@deloitte.com.

May 2016

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May 2016

  • Rev. Proc. 2016-22 Clarifies the Practices for the Administrative Appeals Process in Cases Docketed in the Tax Court
  • Tax Court Determines that Mitigation Applies to Correct an Exclusion of Income at the Beneficiary Level of a Trust
  • Rev. Proc. 2016-19 Updates the IRS’s Industry Issue Resolution Program Procedures
  • IRS Issues Notice Updating List of Designated Private Delivery Services under Section 7502

Archive

March 2016
LB&I Issues Updated Examination Process

January 2016
Changes Made to Partnership Audits and Adjustments

November 2015
Tax Court Invalidates Transfer Pricing Regulations, Finding That They Did Not Satisfy the Reasoned Decisionmaking Standard under “State Farm”

September 2015
The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely

July 2015
A District Court Holds IRS’s Assessment of a Reportable Transaction Penalty was Untimely under Section 6501(c)(10) as IRS Had Been Furnished the Required Information More Than One Year before Assessment

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