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.
- 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
LB&I Issues Updated Examination Process
Changes Made to Partnership Audits and Adjustments
Tax Court Invalidates Transfer Pricing Regulations, Finding That They Did Not Satisfy the Reasoned Decisionmaking Standard under “State Farm”
The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely
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