Category Archives: IRS Rulings & Regulations

Private Letter Ruling Requests

Posted on February 18, 2015 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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IRS & NYS DTF Matters: Recent Developments & 2013 Regs. & Rulings of Note

Posted on February 16, 2014 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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2012 Regulations, Rulings & Pronouncements of Note

Posted on February 14, 2013 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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From The IRS — Recent Developments, August, 2011

Posted on July 27, 2011 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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Significance of IRS Rulings

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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IRS Ruling Blesses New York RLLPs (January 1996)

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

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