| 
On June 5, 2019, the Internal Revenue Service announced 2019 Third Quarter IRS Interest Rates. This quarter, the IRS interest rates will be reduced for the first time in years. 2019 Third Quarter IRS Interest Rates: 3rd Quarter and Interest Rates Defined Third quarter of 2019 begins on July 1, 2019 and ends on September […]
On May 31, 2019, the IRS released a Private Letter Ruling (“PLR”) on the extension of time to make an election to be treated as a disregarded entity for US tax purposes under Treas. Reg. Section 301.7701 (26 CFR 301.7701-3). Let’s explore this PLR 201922010 in more detail. PLR 201922010: Fact Pattern PLR 201922010 deals […]
The 2017 Tax Reform created the Internal Revenue Code Section 965, which requires US shareholders of foreign corporations to pay a new transition tax (hereinafter, “IRC 965 Tax”) in certain circumstances. In this short article, I will introduce the readers to the IRC 965 Tax. IRC 965 Tax: Taxpayers Who Are Targeted by the New […]
On April 16, 2019, the IRS Large Business and International division (LB&I) announced the approval of three additional compliance campaigns. Let’s discuss in more detail these April 2019 IRS compliance campaigns. April 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive planning, the IRS decided to move LB&I toward issue-based examinations and a […]
On May 15, 2019, a Texas federal court ruled that the IRS can enforce a John Doe Summons for client information from Taylor Lohmeyer Law Firm because the firm failed to demonstrate that the attorney-client privilege protected this information. This is bad news for Taylor Lohmeyer Law Firm clients who now may have to face […]