alliantNational Blog

Corporate tax departments need to develop a proactive approach to preparing for increasingly aggressive audits. The US federal government and many state governments are under difficult budgetary constraints and will likely try to raise revenue by taking aggressive audit positions. Additionally, many companies have reported an increase in foreign audits as a result of the…

The Internal Revenue Service issued Announcement 2014-32 on November 10, 2014 to clarify transitional rules regarding the IRS’ new position on IRA rollovers. Internal Revenue Code section 408(d)(3) provides that a distribution from an IRA is excluded from gross income as long as the entire amount is contributed to an IRA within 60 days after…

Congress enacted section 751 of the Internal Revenue Code to prevent both the transformation of ordinary income into capital gain and the shifting of ordinary income among partners of a partnership. The section applies when a distribution alters partners’ share of unrealized receivables and substantially appreciated inventory (“hot assets”). In determining whether a distribution alters…

A partnership tax reform proposal drafted by the House Ways and Means Committee in February 2014 has come back into the news after Mark Warren, Ways and Means majority tax counsel, recently commented on the proposal at a District of Columbia Bar Taxation Section conference. Over the past year, the GAO and other agencies have…

The IRS recently announced a realignment of its compliance operations that will have an impact on individual and small business taxpayers. Effective October 20, tax compliance operations in the Wage and Investment and Small-Business/Self-Employed divisions will be realigned to enhance efficiency and reduce redundancy. According to an October 8th IRS release, “the goal of the…

The Obama Administration continues in its attempt to combat so-called inversion transactions. An inversion transaction occurs when a domestic parent corporation, through a corporate reorganization, becomes a subsidiary of a foreign corporation and the shareholders of the domestic corporation become a substantial portion of the shareholders of the foreign corporation. This allows the US company…

October 17, 2014 William R. Davis The new information document request (IDR) procedures released in the past two years are part of an exam redesign in the Large Business and International Division, former acting IRS Commissioner Steven T. Miller said on October 16. Fred Murray of Grant Thornton LLP said at the American Law Institute…