Growing up my Mom used to say “You’ve made your bed, now lie in it.” Luckily for taxpayers, my Mom is not the IRS. The IRS understands that mistakes happen, conditions change, and deals sour. Under the rescission...
Effective October 1, 2016, the IRS has revised the Internal Revenue Manual (IRM) instructing Appeals Officers that most Appeals conferences will be held by telephone instead of in person. The changes to the IRS are in...
In recently issued Revenue Procedure 2016-49, the Service has confirmed that both a QTIP election and a portability election may be made on the same estate tax return, thereby maximizing exemption planning and flexibility in...
As I discussed in detail in my August 4, 2016 blog post, “Without Further Ado, The Proposed Regulations Under Section 2704”, the new proposed regulations are undoubtedly controversial. In their current form,...
The IRS announced in Rev. Proc. 2016-45¹ that it will once again issue private letter rulings on issues of corporate business purpose and device under §355, after a hiatus of 13 years. Section 355 provides rules...
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