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Category Archives: IRS Rulings & Regulations
Private Letter Ruling Requests
I. Introduction Private letter rulings are in the nature of “advisory” rulings by the IRS concerning the tax implication of income or estate transactions contemplated by taxpayers. As stated in Rev. Proc. 2015-1, the IRS generally issues a letter ruling … Continue reading
Posted in Federal Income Tax, Federal Tax Litigation, IRS, IRS Rulings & Regulations
Tagged effect of letter rulings, effect of PLRs, income tax, irs, IRS letter rulings, Pre-submission conference, Private Letter Ruling Requests, Private Letter Rulings, Rev. Proc. 2015-1, Ruling Request Submission, User Fees for PLRs
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IRS & NYS DTF Matters: Recent Developments & 2013 Regs. & Rulings of Note
I. IRS Matters Final Regulations For Health Insurance As of January 1, IRC § 5000A requires that all “non-exempt” individuals obtain “minimum essential healthcare coverage.” Final regulations governing penalties for noncompliance have been issued. (T.D. 9632). The regulations provide, inter … Continue reading
Posted in Gift & Estate Tax Decisions of Note, IRS, IRS Matters, IRS Rulings & Regulations, NYS Dept. of Tax'n & Finance
Tagged delaware nongrantor trusts, Health Insurance Regulations, irs, late s corporation election, mcneil v. Pennsylvania, net investment income tax, nys suspension of drivers' license tax, nys warrantless income executions, option reporting for brokers mandatory, PLR 201310002, regulations for tangible property, relief from unnecessary qtip elections, Rev. Proc. 2013-35, Taylor v. NYS Tax Commission, treasury
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2012 Regulations, Rulings & Pronouncements of Note
View in PDF: Tax News & Comment — February 2013 2012 Regulations, Rulings & Pronouncements of Note I. Taxpayer Advocate Report National Taxpayer Advocate Nina E. Olson issued the agency’s annual report to Congress on January 9, 2013. The report … Continue reading
Posted in IRS Rulings & Regulations
Tagged Acquiescence, applicable exclusion amount, Chief Council Advisory, estate attorney, identity theft, IRS underfunding, like kind exchange, probate, Revenue Procedures, Revenue Rulings, tax attorney, tax lawyer, tax legislation, Technical Memoranda, treasury regulations
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Significance of IRS Rulings
The Internal Revenue Code, a body of federal law enacted by Congress, is controlling authority in any federal tax dispute. Treasury Regulations, which interpret and expound upon various Code provisions, are also controlling except in the rare circumstance where a … Continue reading
Posted in IRS Rulings & Regulations
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IRS Ruling Blesses New York RLLPs (January 1996)
New York Partnership Law Sec. 121-1500 provides that a professional partnership without limited partners may register as a limited liability partnership (RLLP) by registering with the NYS Department of State. The IRS has ruled that this registration results in seamless … Continue reading
From The IRS — Recent Developments, August, 2011
VIEW IN PDF: Tax News & Comment — August 2011 Approximately one million U.S. taxpayers have at least one financial account located in a foreign country. Many have not reported their offshore accounts to the IRS, a violation with possible … Continue reading →