IRS has revised Notice 2011-53 which provides the phased implementation of the Foreign Account Tax Compliance Act (FATCA) rules that expand the information reporting requirements imposed on foreign financial institutions (FFIs) and impose withholding, documentation, and reporting requirements with respect to certain payments made to specified foreign entities. The revised Notice provides that a withholding agent’s Code Sec. 1472(a) withholding obligations for payment to a non-financial foreign entity with respect to amounts described in Code Sec. 1473(1)(A)(i)

IRS’s Small Business/Self-Employed (SB/SE) Division has reissued interim guidance for directors on the procedures for processing Form 1127, Applications for Extension of Time for Payment of Tax Due to Undue Hardship. Reissuance of Procedures for Processing Form 1127 Applications for Extension of Time for Payment of Tax Due to Undue Hardship The Beliveau Law Group: Massachusetts | Florida | New Hampshire The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and

IRS recently released a comprehensive Attorneys Audit Technique Guide (ATG) for auditors to use in reviewing returns of attorneys. It pinpoints the problem areas that IRS agents are instructed to probe for, explains in detail how attorney audits should be conducted, and lists the types of documents that should be requested and examined. Attorneys Audit Technique Guide The Beliveau Law Group: Massachusetts | Florida | New Hampshire The attorneys at The Beliveau Law Group provides legal

In PLR 201128017,IRS has privately ruled that contracts offered by a life insurance company to certain investment account owners that obligate the company to pay a benefit if a customer’s account falls below a specified value, are annuity contracts under Code Sec. 72. Accordingly, any such benefits paid to the customers will be considered “amounts received as an annuity,” and the fees paid by the customers for the contracts will be factored into their investment in

In Kasper, the tax court reaffirmed its decision in Cooper v. Commissioner, 135 T.C. 70 (2010), each Whistleblower Office letter that denies a whistleblower claim is a determination within the meaning of sec. 7623(b)(4), I.R.C.  The Tax Court has jurisdiction to review the matter, because it is a final administrative decision. The Beliveau Law Group: Massachusetts | Florida | New Hampshire The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and

In PLR 1126002 IRS has privately ruled that warrants issued from a parent corporation to a shareholder as part of an exchange for the shareholder’s stock in the parent won’t be treated as exercised on the date of the exchange under Code Sec. 382(l)(3)(A)(iv) and Reg. § 1.382-4(d)(2). The shareholder also won’t be treated as owning any stock in the parent for purposes of Reg. § 1.382-3(j)(3)’s cash issuance exception immediately before the parent’s subsequent issuance and

Notice 2011-62 provides a proposed revenue procedure that will update Rev. Proc. 2000-43, 2000-2 C.B. 404, which provides guidance regarding ex parte communications between Appeals and other Internal Revenue Service functions. The Beliveau Law Group: Massachusetts | Florida | New Hampshire The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation