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Supreme Court Refuses to Hear “Amazon-Tax” Case

On December 2nd, 2013 the Supreme Court of the United States denied certiorari in Overstock.com, Inc. v. New York State Department of Taxation and Finance, et al. The case involved the assessment of State sales tax against online retailers. The case, brought by Amazon.com and other online retailers, challenged New York State’s law imposing sales…

IRS Updates Guidance on Offers in Compromise Rejected on “Public Policy” and “Not in the Best Interests of the Government” Grounds

On October 23rd, 2013 the Internal Revenue Service (“IRS”, “Service”) issued a memorandum providing guidance to collections employees regarding the proper criteria and procedures for rejecting offers in compromise under the “not in the best interest of the government” and “public policy” standards. Regarding rejections under the “not in the best interest of the government”…

IRS Ruling on SRLY Limitation Allows Surviving Subsidiary to use Pre-Reorganization Losses

The Internal Revenue Service (“IRS”) issued Private Letter Ruling 105886-13 on July 15th, 2013 regarding the treatment of a subsidiary’s post-merger net positive income, net capital gain and Internal Revenue Code (“IRC”) 38(c) contributions for the purpose of computing a Separate Return Limitation Year (“SRLY”) subgroup’s consolidated net income, consolidated net capital gain and consolidated…

IRS Updates § 199 Guidance for Contract Manufacturing Benefits and Burdens of Ownership in Response to Tax Court Case

On October 24th, 2013, in Advo, Inc. & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent (“Advo”), 141 T.C. No. 9, the United States Tax Court held that the taxpayer did not have the “benefits and burdens of ownership” of the direct advertising materials, and was therefore not entitled to the IRC section 199 Domestic…

New LB&I Information Document Request Policy Clarified

On Monday, November 4th, IRS Commission of the Large Business and International Division (“LB&I”), Heather Maloy, issued a memorandum (LB&I-04-1113-009) clarifying updates to the Information Document Request enforcement process. In June of 2013, the Service announced (in LB&I-04-0613-004) new protocols for issuing and enforcing Information Document Requests (“IDRs”), the most common tool used by IRS…

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aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2021 alliantNational. - All Rights Reserved.

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