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The article focuses on the requirements and process for partnerships to file an administrative adjustment request (AAR) under the Bipartisan Budget Act of 2015 (BBA). It details how the centralized partnership audit regime shifts tax liability to the partnership, the calculation of imputed underpayments, and the specific forms and procedures necessary for compliance.

The article delves into the intricacies of managing transfer pricing adjustments, particularly focusing on taxpayer-initiated adjustments and their implications. It highlights that taxpayers in the U.S. can proactively adjust their transfer prices on their original, timely filed U.S. returns to achieve arm's-length results and avoid penalties. It emphasizes the importance of careful consideration and communication with tax authorities in managing these adjustments.

The article primarily focuses on the importance of reporting foreign assets and gifts accurately to comply with federal tax requirements for U.S. taxpayers. It highlights the complexities involved in these reporting obligations and the potential civil and criminal penalties for non-compliance. It outlines options for resolving prior non-compliance and stresses the significance of collaboration with tax professionals to navigate these reporting obligations effectively.

The article examines the complexities and nuances of state conformity to the federal Internal Revenue Code, highlighting how states adopt, incorporate, and sometimes deviate from federal tax laws. It discusses the practical and substantive issues that arise from state conformity, including retroactive tax provisions, state-specific decoupling from federal provisions, and the administrative burdens these can create for taxpayers.

The article focuses on the enforcement phase (Phase 2) of VAT (Value-added tax) regulations for remote sellers in the digital economy. It discusses the challenges faced by tax authorities in identifying noncompliant remote sellers and the various enforcement measures implemented to ensure compliance, ranging from gentle reminders to aggressive actions such as blocking internet access and imposing criminal penalties.

The article focuses on the challenges and implications of continuous transaction control (CTC) systems, specifically electronic invoicing (e-invoicing) mandates, on intercompany transactions. It highlights the rapid global adoption of CTC systems, which require real-time or near-real-time submission of transactional data to tax authorities. It addresses the complexities faced by multinational corporations in complying with these mandates.

The article focuses on understanding the updated tax ethical standards, particularly the revised AICPA (American Institute of Certified Public Accountants) Statements on Standards for Tax Services (SSTSs). It provides a general overview of the revised SSTSs, organized into four parts, and includes practical illustrations of how to apply the new tax standards. key areas covered include general standards, tax compliance services, tax consulting services, and tax representation services.

The article focuses on helping tax professionals engaged in compliance and planning to prepare clients for potential civil or criminal federal tax enforcement actions. It emphasizes the importance of maintaining well-organized client records and documentation to ensure timely compliance with U.S. Internal Revenue Service (IRS) demands, as well as the need to involve an attorney early in case of potential criminal matters.

The article focuses on the inadvertent-error exception to identifying hedging transactions for tax purposes. It explains that taxpayers often enter into hedging transactions to manage risks in their trade or business, such as interest rate risk or currency fluctuations. It further presents examples of letter rulings and Chief Counsel Advice memorandums that shed light on the IRS's (Internal Revenue Service) position regarding inadvertent errors.

The article focuses on the impact of the Supreme Court's decision in South Dakota v. Wayfair, Inc., which changed sales tax collection obligations for remote sellers. It discusses the expected and unexpected effects of the ruling, including the adoption of economic nexus laws and lack of uniformity in definitions and compliance responsibilities. It also provides insights into the challenges faced by taxpayers in complying with the evolving tax regulations.

The article discusses the admissibility of blog posts in an innocent-spouse relief case. It is reported that the Tax Court held that posts from a personal blog, which has been relevant to the disposition of the taxpayer's claim, were admissible in a Tax Court case seeking determination of the appropriate relief under Section 6015(f). It further discusses the background of the case, the arguments made by both parties, the relevant law, the Tax Court's decision, and reflections on the case.

The article reports that the U.S. Internal Revenue Service (IRS) determined that an employer funding an international assignee's federal income tax obligations under a tax equalization policy. It mentions impact of global mobility tax compliance processes on an employer's federal income tax reporting and withholding obligations. It also mentions assignment allowances inflate an assignee's taxable earnings, and, in turn, increase the assignee's personal tax liability.

The article examines the various federal income tax issues to be mindful of in these circumstances and effect of a partner's death on a Subchapter K partnership. It mentions consequences of a shareholder's death on a Subchapter S corporation, and finally looks at the tax effects of death for the individual owner. It also mentions complications for a partnership in the tax compliance and planning process and inheritance or testamentary transfer.

The article reports that the U.S. Internal Revenue Service (IRS) was able to promptly process 85 percent of returns in the 2022 filing season and expedite its resolution of some of the most common taxpayer errors, the Service's backlog of paper-filed returns bogged down further. It mentions report also lists internal goals and objectives for the Taxpayer Advocate Service (TAS) Collins heads. It also mentions paper tax returns the IRS had still to process.

The article focuses on new economic nexus rules took effect for the Illinois retailers' occupation tax (ROT), which is the sales tax imposed on tangible personal property sales, and the related use tax. It mentions Illinois nexus rules is that many retailers and other businesses are now facing an array of Illinois tax collection scenarios that may challenge their existing tax compliance systems. It also mentions changes significantly affect remote retailers' sales into the state.

The article provides a summary of options available to taxpayers for compliance with their foreign financial asset filing requirements in the U.S. It mentions that the taxpayers who have failed to report or pay all the tax due on income related to the assets may be able to voluntarily come into compliance through the Voluntary Disclosure Practice, the streamlined filing compliance procedures, and the Report of Foreign Bank and Financial Accounts and information return submission procedures.

The article focuses on various research related to taxation published in various tax journals in the U.S. It mentions a study in "The Journal of the American Taxation Association" which examined the relationship between tax professionals and their clients during a disagreement. It cites a field experiment conducted with the Colorado Department of Revenue (DOR), which found that small changes to the wording of delinquent income tax notices can increase taxpayers' compliance.

The article reports that U.S. President Joe Biden signed into law the Infrastructure Investment and Jobs Act which provisions is the reinstatement and modification of the Superfund excise tax on chemicals and imported taxable substances. It mentions Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) was enacted to create a hazardous substance. It also mentions taxpayers should develop excise tax compliance procedures and reporting processes.

The article offers information on how practitioners benefit from academic tax research. It addresses issues related to tax compliance, tax policy, tax planning, tax reporting, tax incentives and an assortment of tax behaviors. It mentions that leading organization of tax academics as the American Taxation Association.

The article reports that country-by-country (CbC) reporting provisions has increased the amount of information available to tax authorities, which in theory has enabled them to perform better high-level assessments of transfer-pricing risk. It mentions CbC reporting requirements have imposed new compliance burdens on large multinationals (MNEs) that are subject to the provisions. It also mentions bilateral income tax treaty or a tax information exchange agreement (TIEA).

The article focuses on 2019 tax year brings a welcome opportunity to take a second look at reclassifying older assets as repairs and maintenance expenses under the tangible property regulations. It mentions rules allowed an opportunity to correct certain past items not in compliance with the new regulations through an automatic change in accounting method. It mentions taxpayers that once again need to consider the tangible property regulations due to improper implementation.

The article focuses on private foundations and donor-advised funds with Certified Public Accountant (CPA) who have combined tax compliance and personal financial planning services have most likely experienced the considerable satisfaction. It mentions charitable giving and philanthropy provide an excellent example of the two disciplines coming together and investment advisers have a need to rebalance or sell securities to generate cash. It also mentions tax compliance services.

The article focuses on technological analytics and interconnectedness have led to increasing automation of tasks in the corporate tax function. It mentions tax automation must overcome other barriers to implementation in the organization, including demonstration of a meaningful return on investment and training and support to tax staff in the use of robotic process automation. It also mentions automating manual adjustments to monthly sales tax return data for the company's sales tax compliance.

The article reports that U.S. Internal Revenue Service (IRS) has released its Relief Procedures for Certain Former Citizens and their U.S. citizenship to comply with their U.S. income tax and reporting obligations without paying any unpaid taxes and penalties. It mentions streamlined procedures remain an option for higher-net-worth individuals to remedy tax noncompliance preceding expatriation. It also mentions U.S. citizen status because the Foreign Account Tax Compliance Act (FATCA).

The article offers suggestions to avoid or contest for information return penalties. It mentions information returns is essential to tax compliance, the penalties imposed for failing to file correct or timely returns and U.S. Internal Revenue Service (IRS) will not impose the penalties under Secs. 6721, 6722, and 6723. It also mentions penalties subject to deficiency procedures can be challenged in Tax Court before they are paid.

The article reports that U.S. Tax Court held that a purported notice of deficiency issued to a taxpayer, which consisted of four documents, two of which identified the taxpayer and two of which identified another related taxpayer. It mentions U.S. Internal Revenue Service (IRS) issued a set of documents that it contended was a notice of deficiency and IRS determined tax deficiencies for fiscal years 2003 and 2007.

The article focuses on the use of Industry Issue Resolution (IIR) Program is one of many compliance programs used by U.S. Internal Revenue Service (IRS) in resolving contentious tax issues. It mentions IRS uses to resolve those issues include the Compliance Assurance Process (CAP), the Pre-Filing Agreement Program, and private letter rulings. It also mentions IIR approach to issue resolution is a strength-in-numbers strategy.

The article reports that the U.S. Internal Revenue Service (IRS) asking to schedule an appointment to examine the client's compliance with the requirement to file Report of Foreign Bank and Financial Accounts (FBAR). It mentions the U.S. Department of Justice has succeeded in several cases where courts have upheld the maximum FBAR willfulness penalty. It also mentions meaning of willfulness to meet its burden of proof.

The article focuses on integral program that all firms should consider embracing with mentoring program. Topics discussed include merits of establishing a tax-specific mentoring program and mentoring is one of the keys to succession planning, tax compliance services particularly tax return preparation services and relation between artificial intelligence, tax reform, and other outside factors, the profession is evolving for the next generation.

The article informs on Large Business and International Division campaigns announced by the U.S. Internal Revenue Service. It mentions that the campaigns are designed to select returns with identified potential compliance risks; and the efforts of campaign in improving return selection, and identifying issues representing a risk of noncompliance.

The article highlights challenges related to tax compliance function as observed by seniors in the U.S., as of October 2018. Topics discussed include non-availability of Form 1040EZ, Income Tax Return for Single and Joint Filers With No Dependents, to older taxpayers; no relief under Form 1040A, U.S. Individual Income Tax Return, to seniors; and provisions of the Bipartisan Budget Act of 2018 (BBA) to alleviate the burden from seniors.

The article reports that the U.S. Internal Revenue Service (IRS) has announced changes that allow taxpayers to argue reliance on Service-issued frequently the IRS may apply this fact sheet. It mentions FAQs did not constitute reasonable cause under the various Internal Revenue Code penalty provisions that afforded a reasonable-cause exception. It also mentions federal tax law controls a taxpayer's tax liability.

The article focuses on the streamlined filing compliance procedures which was introduced in 2012 for individuals residing outside the U.S. offers a alternative to the Offshore Voluntary Disclosure Program (OVDP) for qualifying taxpayers to disclose unreported foreign assets and income. It mentions that streamlined procedures are available only to taxpayers failed to report assets and income and file required information returns was due to no willful conduct and for income tax purposes.

The article discusses how common reporting standard (CRS) is affecting financial services institutions in the U.S., as of March 2016. Topics discussed include implementation of the Foreign Account Tax Compliance Act (FATCA); CRS standards for automatic exchange of financial account information (AEOI) developed by the Organisation for Economic Cooperation and Development (OECD), and differences between CRS and FATCA.

The article reports that the U.S.Treasury Department and the Internal Revenue Service (IRS) has published proposed and temporary regulations under Sec.199 that will address several issues including contract manufacturing, W-2 wages for acquisitions and hedging transactions. It states that Sec. 199 allows a taxpayer to deduct 9% of the lesser of the taxpayer's qualified production activities income for the tax year and Sec.199 allows taxpayers to remain eligible in case of short tax years.

The article focuses on the tax compliance for business in the U.S. Topics discussed include imposition of business and occupation tax (B&O) under the Public Law (P.L.) 86-272 in Washington, imposition of commercial activity tax (CAT) in Ohio, imposition of economic nexus under the Revenue Modernization Act (RMA) in Tennessee, and adoption of economic nexus standard in New York for corporate income tax.

The article focuses on the Section 6676 in the U.S., which imposes a penalty on a taxpayer who files a claim for refund or credit of income tax in an amount that is determined to be excessive. Topics include prior to the enactment of Sec. 6676, a taxpayer could take an aggressive position on a claim for refund, and the Sec. 6676 penalty is stated to be equal to 20 percent of the excessive amount by which the claim for refund or credit exceeds the amount allowable for the tax year at issue.

The article reports on the tax exemption regulations for nonprofit hospitals issued by the U.S. Internal Revenue Service (IRS) under Section 501 (r) on December 29, 2014. It mentions the impact of regulations on financial assistance policies (FAPs), community health needs assessments (CHNAs) and billing and collection process. It adds that the regulations aims to promote compliance in hospital facilities.

The article focuses on the withholding agents in the U.S. Topics discussed include U.S. withholding tax imposed on payments of U.S.-source income to foreign persons, the U.S. Tax Court in the case Casa De La Jolla Park, Inc.,94 T.C. 384 indicated that interposing a third party between the payer and the payee will not relieve the payer's liability when the payment is made by third party at the payer's direction and from the payer's funds, and noncompliance taxpayers' transactions.

The article reports on a regulation issued by the U.S. Internal Revenue Service (IRS) under Sections 162 and 263 to provide guidance on amounts paid to acquire, produce or improve tangible property. Topics includes effective date of regulation on January 1, 2014, impact of final regulations for purposes of compliance with tax regulations as well as accounting for income taxes under Accounting Standards Codification (ASC) Topic 740 and key provisions under tangible property regulations.

The article reports on the updates made by the U.S Internal Revenue Service regarding taxpayers' compliance with the U.S Patient Protection and Affordable Care Act (PPACA) related issues. Topics discussed include compliance efforts centered on the premium premium tax credit and the individual shared responsibility payment and the Coverage Data Repository (CDR), a database that pre-positions tax returns at the time of filing for premium tax credit qualification.

The article discusses the tax benefit rules for business owners of U.S. charitable remainder trusts (CRTs), donors, charitable lead trusts (CLTs) and private foundations. The private foundation owner's compliance with U.S. income taxes, including in regard to self-dealing, the unrelated business income tax (UBIT) and deductions they can receive under U.S. tax regulations, is provided.

The article presents a U.S. state trust and estate income tax return checklist for 2013. Topics include state income tax compliance for trustees, why trusts operate as flowthrough entities for tax purposes, and the integration of fiduciary trust accounting and income taxation. Information is provided on the use of the checklist by tax practitioners to ensure trust and estate tax compliance.

The article focuses on guidance from the U.S. Internal Revenue Service (IRS) on the deductibility of fines and penalties from taxpayers. It is noted that the regulations provide guidance on Sec. 162(f), which was amended by the law known as the Tax Cuts and Jobs Act (TCJA). It mentions that the final regulations were effective from January 19, 2021.

The article offers information on various circumstances that arises the need of an experienced criminal tax attorney in a potential criminal tax matter under the U.S. Internal Revenue Service (IRS). It informs about the fraud technical advisers (ITAs), trained and an experienced agent, which assist employees seeking tax compliance in development of a plan of action for establishing evidence of fraud and making timely referral.

This two-part article explains the procedures and tax compliance issues that fiduciaries face before domestic trust or estate distributions are paid or allocated to foreign beneficiaries. Part I explains how to verify the tax status of foreign beneficiaries for U.S. tax purposes and calculate the net distribution amount after properly withholding tax payments. Part II, in the January issue, will contain a comprehensive example of calculating the net distribution amount and calculating the withholding tax on income items for beneficiaries residing in various foreign countries, as well as the application of certain tax treaty benefits. [ABSTRACT FROM AUTHOR]

The article focuses on U.S. taxation on foreign pension plans. Topics include the exemption for unfunded deferred compensation arrangements prior to distribution, taxation on contributions to a nonexempt employees' trust, and the substantial risk of forfeiture. Information is provided on annuity starting dates and taxation on pension fund interest.

The article reports that the U.S. Internal Revenue Service (IRS) issued a draft of Schedule Uncertain Tax Position Statement (UTP) with Announcement 2010-30. In 2010, the Schedule UTP will be required for corporations that have total assets in excess of 10 million U.S. dollars. The completion of Schedule UTP is expected to result to more tax compliance costs for business in its jurisdiction.

The article discusses tax amnesty programs and voluntary compliance initiatives (VCIs) as a way to control declining state revenues in the U.S. It cites the disadvantages of such programs to taxpayers, including post-amnesty penalties to be imposed on those who will not be able to pay qualified delinquencies during the amnesty period. Also noted is the connection between the increase in amnesty programs and the economic condition of the country. It is added that VCIs are aimed at taxpayers involved in tax shelter transactions.

The article focuses on developments affecting individual taxation in the U.S. It says that the Small Business and Work Opportunity Tax Act of 2007 raised the age requirements for Sec. 1(g) effective for tax years after May 2007. It notes that final regulations on the child and dependent care credit clarify that expenses for a child in kindergarten or higher grades do not qualify for the credit. Recommendations in the report "Reducing the Federal Tax Gap: A Report on Improving Voluntary Compliance" are cited, such as enhancement of taxpayer service.