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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…

Fast Track Settlement Program Expanded Nationally in IRS Small Business / Self Employed Division

In a press release dated November 6, 2013, the IRS Small Business/Self Employed Division (“SB/SE”) announced the nationwide availability of the Fast Track Settlement (“FTS”) program. Fast track settlement is an alternative dispute resolution option for taxpayers in examination. It allows the taxpayer and IRS auditors to meet collectively to resolve a case without resort…

IRS Filing Season Delayed Due to Government Shutdown

On October 22, 2013, the Internal Revenue Service announced it will delay the 2014 filing season approximately one or two weeks to provide the necessary time to sufficiently program and test its tax processing systems. This will move the original start date of the filing season from January 21st until sometime in the period of…

IRS Failed to Comply with Taxpayer Property Seizures

On June 12, 2013, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report reviewing IRS compliance with legal guidelines when conducting seizures of taxpayers’ property during a fiscal year period ending June 30, 2012.  TIGTA reviewed a random sample of 50 of the 738 seizures that occurred during the fiscal year ending June…

LB&I Announces Changes to Information Document Request Process

On June 18th, 2013, the Large Business and International Division (LB&I) of the IRS released a memorandum (LB&I-04-0613-004) outlining changes to the Information Document Request (“IDR”) process. In particular, the IRS provided that all IDRs issued after June 30, 2013, must be issue focused, they must be discussed with the taxpayer, and the taxpayer and…

Hawaii re-establishes State R&D Tax Credit

On July 9, 2013, Hawaii Governor Neil Abercrombie (D) signed bill SB 1349 , which reestablished the research and development tax credit for qualified research activities. The State credit tracks the federal credit for increasing research activities found at I.R.C. § 41, thus providing consistency between Federal and State standards. Taxpayers must be claiming the…

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

© 2023 alliantNational. - All Rights Reserved.

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