Owe the IRS? Passports at Risk Under New Code Sec. 7345Colvin, John M.Taylor, Claire H.Journal of Tax Practice & Procedure
In conventional (Error Detection and Correction) EDC mechanism, Single Error Correction and Double Adjacent Error Detection (SEC-DAED) are done by using Hamming Code. In order to detect the triple adjacent error in SEC-TAED, it is required to add one more parity bit, which consumes more ...
Code Sec. 7433: Damages Against the IRS for Wrongful Collection ActionsJohnson, Steve R.Journal of Tax Practice & Procedure
The article offers information on the Code Section 355 of the LTR 201001009 that has been devised by the U.S. Internal Revenue Service. The regulation allows controlled foreign corporation (CFC) to distribute of all the stock of its parent company in the U.S. Also, it permits taxpayers to...
Owe the IRS? Passports at Risk Under New Code Sec. 7345.The article examines a provision in the Fixing America's Surface Transportation (FAST) Act, enacted in December 2015, authorizing the government to revoke or deny an individual's passport if they owe the Internal Revenue Service (IRS)....
IRS Issues Proposed Regulations of Code Sec. 1446 withholding Obligations of Partnerships with Foreign Partners, Thecertificate such as a Form W-8BEN or Form W- 81MY containing the information necessary tosupport 754. The Proposed Regulations also provide guidance concern- ing capital losses,suspended...
Deemed Dividends Without Cash—New IRS Proposed Code Sec. 305(c) Regs Trigger Outcry and Create Challenges for Convertible Debt, Stock and RightsOn April 13, 2016, proposed regulations under Code Sec. 305(c) were published (the "Proposed 305(c) Regs").1 The Proposed 305(c) Regs clarify ...
Section 956 of the Internal Revenue Code of 1986 (" the Code") is a double-edged sword that can be wielded by both the 1RS and the taxpayer. As discussed in greater detail below, Code Sec. 956 provides the 1RS with a tool for taxing a" US shareholder" of a" controlledGlicklich, ...
IRS Targets Abuse of Qualified Tuition Programs (Code Sec. 529 Plans).The article reports that the U.S. Internal Revenue Service (IRS) has proposed a regulation designed to curb a perceived abuse of qualified tuition programs. The IRS alleges that abuse may arise if a person contributes a ...
SEC Staff Said to Discuss Floating NAV for Money Funds With IRSChristopher CondonDave Michaels