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...
You are probably familiar with the idea of an IRA rollover. Generally, taxpayers can distribute assets from an IRA account, without an immediate tax consequence, provided that the assets are contributed to another IRA account...
On July 18, 2016, the IRS released for the first time the procedure for amending a streamlined submission, as part of ongoing updates to its Frequently Asked Questions for U.S. Taxpayers Residing in the United States...
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