Overview
IRS Advisory Council Issues 2018 Annual Report: Today, the IRS Advisory Council released its 2018 annual report, which includes recommendations to the IRS regarding new and continuing tax administration issues. The report covers topics and concerns, including, in particular, the IRS budget, electronic third party authentication, transfer pricing documentation, and the update of Circular 230.
IRS Releases 2019 Inflation Adjustments: Today, the IRS issued Rev. Proc. 2018-57, which contains the inflation adjustments for more than 60 tax provisions, including tax rate schedules and other changes. The adjustments are generally used for tax returns filed in 2020.
Second Circuit Upholds Jurisdiction Where Notice of Deficiency Misstated Tax Year End: In a summary order issued today, the Second Circuit held that the Tax Court had subject matter jurisdiction despite the fact that the IRS’s notice of transferee liability contained an incorrect tax year end date. The taxpayer asserted that the incorrect date invalidated the notice. However, the court found that the notice was sufficient because it named the taxpayer, the amount of the deficiency and a taxable year, and the basis for the deficiency. The case is Diebold Foundation, Inc. v. Comm’r.
OECD Requests Taxpayer Input on Dispute Resolution Peer Reviews: The OECD requested taxpayer input on specific issues relating to: access to the Mutual Agreement Procedure (MAP); the clarity and availability of MAP guidance; and the timely implementation of MAP agreements for the following jurisdictions: Brazil, Bulgaria, China, Hong Kong, Indonesia, Papua New Guinea, Russian Federation, and Saudi Arabia. Responses to the OECD’s questionnaire are due December 13.
IRS Reminds Taxpayers of Changes to Business Taxation: Today, the IRS reminded business taxpayers of certain changes in the 2017 Tax Cuts and Jobs Act, including rate changes applicable to pass-through entities, increases to the expensing of business property, and expansions to bonus depreciation.