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This is a reminder that the 2011 Offshore Voluntary Disclosure Initiative (OVDI) will expire on August 31, 2011. The 2011 OVDI was announced on February 8, 2011, and follows the 2009 Offshore Disclosure Program (OVDP). The 2011 initiative offers clear benefits to certain taxpayers who currently face far higher penalties along with potential criminal charges […]
The IRS is currently examining new procedures and policies regarding transfer pricing audits. Recently, the IRS developed a “Transfer Pricing Practice” within its Large and Mid-Size Business (LMSB) operating division, and last August, the IRS realigned its Large Business & International (LB&I) operating division to handle international tax matters more effectively. The Service intends to […]
On August 5, 2011, the Internal Revenue Service issued guidance on the treatment of basis for certain estates of decedents who died in 2010. The guidance assists executors who are making the choice to opt out of the estate tax and have the carryover basis rules apply. Form 8939, the basis allocation form required to […]
On July 27, 2011, the IRS announced that it is taking additional steps in its continuing efforts to improve the agency’s international operations. First, the IRS Advance Pricing Agreement (APA) Program, concerned exclusively with reaching pre-filing agreements with taxpayers on transfer pricing, will shift from the office of IRS Chief Counsel to an office under […]
On July 15, 2011, the IRS advised truckers and other owners of heavy highway vehicles that their next federal highway use tax return (which is usually due on August 31) will instead be due on November 30, 2011. IRS Notice 2011-77 explains that the main reason for the extension of the deadline is to alleviate […]