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...
In a previous post (click here), I discussed the civil statute of limitations (SOL) the IRS has for assessing additional tax, penalties and interest against a taxpayer. In this post, I will briefly discuss the SOL for...
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