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Tag Archive for Tax Practitioners

IRS Issues IPUs For CFCs & Subpart F Income, Which State Their Subpart F Audit Positions!

Ronald Marini picture30

On October 13, 2015 we posted LB&I Agents Lose Autonomy To Centralized Office That Will Be Using Data to Identify Compliance Risks For Audit!, where we discussed that tax practitioners will face new questions from examination teams as the IRS selects compliance risks based on data, in the Large Business and International Division’s (LB&I) move from individual audits of multinationals to broader considerations involving risk assessment.

While LB&I is scheduled to implement the new structure in early calendar year 2016, in recently released new International Practice Units (IPUs), the IRS has provided additional guidance to its examiners on the audit of foreign base company sales income (FBCSI), a category of subpart F income. These IPUs focus on supply chain structures with foreign sales and/or manufacturing branches (including disregarded entities) that may be used by U.S. multinationals to avoid the application of the FBCSI rules. Read more

LB&I Agents Lose Autonomy To Centralized Office That Will Be Using Data to Identify Compliance Risks For Audit!

Ronald Marini picture19

Tax practitioners will face new questions from examination teams as the IRS selects compliance risks based on data, in the Large Business and International Division’s (LB&I) move from individual audits of multinationals to broader considerations involving risk assessment.

As opposed to the exam team coming out and identifying what areas will be looked at; the issues will be per-identified for  the revenue agent. This change shifts the responsibility of selecting items to examine in an audit from the field agents to the revenue agents who are analyzing data in a centralized office. Exam teams will however, have the ability to raise other issues not identified from the data. LB&I Commissioner Douglas W. O’Donnell said that LB&I will be reorganizing its exam structure to save resources and create a more Read more

SARS Is Aggressive – Recent Complaints In The South African Parliament

Daniel Erasmus1

There are extensive rights that are available to taxpayers at the commencement of an audit in South Africa.

They are contained in the Tax Administration Act (TAA), the Constitution and the Promotion of Administrative Justice Act. These issues are dealt with in the series of presentations that revolve around tax controversies in Africa and South Africa by Dr Daniel N. Erasmus, a tax controversy specialist in Africa, who resides and consults from the USA. What follows is a recent article published in South Africa about the aggressive moves by SARS:

ARTICLE – THE South African Revenue Service (SARS) is adopting more aggressive tactics to extract information from taxpayers as it tries to achieve a revenue target during a Read more

Tax Planning On The Edge

Young businessman standing on edge of rock mountain
Ride Or Die In The International Tax Arena

The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to violate U.S. laws as long as their advice is legal abroad while others evade taxes in foreign countries without breaking rules in the U.S. However, if you’ve been exploiting the legal arbitrage opportunities resulting from the gaps created by the interaction of different regimes, expect the IRS to go ‘ejecto seato, cuz’ on you and your clients very soon. Read more

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