IRS Insights


IRS Insights

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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November 2014

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November 2014

  • IRS Memorandum Addresses the SB/SE Division’s Use of the New IDR Enforcement Process in Employment Tax Examinations
  • IRS Analyzes Whether Third-Party Employment Tax Returns Were Sufficient to Start Assessment Statute of Limitations
  • Tax Court Analyzes Assessment Statute of Limitations for Excise Tax under Section 4979A
  • Federal Court of Claims, Applying the Relation Back Doctrine, Dismisses Foreign Tax Credit Refund Claims as Untimely
  • IRS Issues Memorandum for Estate and Gift Tax Employees Announcing New Timeframes for Estate and Gift Tax Cases Subject to Appeals Jurisdiction
  • New IRS Guidance Highlights the Authority That Can Be Granted to Employees Pursuant to an LB&I Examination Plan
  • IRS Releases Additional Guidance on the Codified Economic Substance Doctrine


September 2014
IRS Memorandum Provides Implementation Guidance for Phase 2 of the AJAC Project

July 2014
District Court Concludes that Attorney-Client/Tax Practitioner Privileges and Work Product Doctrine Did Not Protect Tax Memorandum from Disclosure in Summons Enforcement Case

May 2014
IRS Provides for Automatic Determination Under Treas. Reg. § 1.1502-75(b) to Treat a Subsidiary that Failed to File a Form 1122 as Joining in the Making of a Consolidated Return by the Affiliated Group

March 2014
Ninth Circuit Affirms in Part and Reverses in Part District Court Decision, Holding that IRS Timely Assessed Tax on Lower-Tier Partnership for Liability Attributable to Partnership Flow-Through Items of Upper-Tier Partnership where Extension Agreements Referred to Upper-Tier Partnership Only

January 2014
U.S. Supreme Court Holds Valuation Misstatement Penalty May Apply When Underlying Deduction or Credit is Disallowed for Reasons Not Specifically Attributable to a Valuation Overstatement

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