IRS Insights

Perspectives

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

January 2015

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January 2015

  • For Taxpayer who Underwent Statutory Mergers, the Court of Federal Claims Allows Interest Netting on Pre- and Post-Merger Underpayments and Overpayments
  • The Ninth Circuit Deals Another Blow to the IRS’s Proposed Transferee Liability Analysis under §6901
  • The Joint Committee on Taxation Review Threshold for C Corporation Refunds has been Raised to $5,000,000
  • Large Business & International Division Issues Directive Related to Section 166 Deductions for Eligible Debt and Eligible Debt Securities
  • IRS Updates Post-Appeals Mediation Guidelines with Revenue Procedure 2014-63
  • IRS Releases Final Regulations Concerning the Manner of Filing Form 5472

Archive

November 2014
IRS Memorandum Addresses the SB/SE Division’s Use of the New IDR Enforcement Process in Employment Tax Examinations

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

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