Welcome to the bimonthly publication IRS Insights, produced by Deloitte's
Tax Controversy Services Group to keep our clients abreast of current issues related to the Internal Revenue Service.
In this month's issue:
· IRS Provides Guidance for SEC Disclosure of Listed Transaction Penalties – On August 15, 2005, the IRS issued Rev. Proc. 2005-51, which sets forth the form, content and timing of SEC disclosures for certain reportable transaction penalties that taxpayers are required to make pursuant to section 6707A(e) of the Internal Revenue Code.
· Appellate Court Holds that the IRS Cannot Offset Erroneous Statutory Interest Outside the Applicable Limitation Period – The United States Court of Appeals for the Federal Circuit recently held that the IRS was not entitled to offset erroneous interest previously paid to a taxpayer against a subsequent refund relating to the same tax year when suit to recover the erroneous interest was otherwise barred by the statute of limitations.
· Tax Controversy Update: Technical Corrections to Certain Reportable Transaction Penalty Provisions – Congress introduced the Technical Corrections Act of 2005. The bill contains modifications to a variety of recently enacted tax legislation, including clarifications with respect to certain reportable transaction penalty provisions.
· Tax Controversy Update: Temporary Regulations Regarding Returns Prepared by the IRS – The IRS and Treasury have issued temporary regulations under section 301.6020-1T, which outline specific rules that IRS personnel must follow when preparing substitute tax returns. The regulations generally provide the IRS with authority to prepare tax returns on behalf of taxpayers who fail to file a return or otherwise file a false, fraudulent or frivolous return.
· Recent Guidance
See attached file for details.
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IRS Provides Guidance for SEC Disclosure of Listed Transaction Penalties
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Last Updated: April 12, 2006
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Source: Deloitte & Touche USA LLP - United States (English)
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