Daily Tax Update - January 31, 2005

IRS EXTENDS TRANSITIONAL RELIEF FOR DISCLOSURE OF REPORTABLE TRANSACTIONS
Today, the IRS issued Notice 2005-17, which provides an extension of the transitional relief period provided in Notice 2004-80 for material advisors to comply with the new reportable transaction filing requirements under section 6111.

  • The Service and Treasury intend to provide further guidance on the issue of the date on which a person becomes a material advisor with respect to a reportable transaction (including whether the obligation of a material advisor arises only when a reportable transaction is entered into by a taxpayer). Because further guidance is under consideration, the transitional relief provided in Notice 2004-80 for disclosure of a transaction under ยง 6111 is extended. If a person becomes a material advisor after October 22, 2004, and on or before January 29, 2005, that material advisor must file the return before March 1, 2005.
  • The notice can be accessed here
  • For additional information, contact Mark J. Silverman, Matthew D. Lerner, or Brian P. Kaufman.

TAX REFORM PANEL SCHEDULES FIRST MEETING
On February 16, the President's Advisory Panel on Federal Tax Reform will hold its first meeting to hear testimony from invited witnesses on general background information  about the federal tax code. The witness list will be released at a later date. This  meeting is the first in a series of public  meetings that the panel will hold before it submits its final report  by July 31.

STEPTOE & JOHNSON LLP - TAX PRACTICE
Steptoe & Johnson LLP has one of the largest and most diverse law firm tax practices in the country. The practice covers the entire spectrum of federal taxation, including representation of businesses before the Congress, Treasury and the national office of the IRS; transactional planning for domestic and multinational corporations; complex audit and controversy work for corporations and other business interests contesting IRS adjustments; litigation before the Tax Court, Court of Federal Claims, district courts, courts of appeals and the Supreme Court. The firm's tax practice also encompasses all aspects of employee benefits (ERISA), executive compensation, tax-exempt organizations and charitable giving.  Steptoe has an extensive state and local tax practice, representing an array of business clients on complex sales and use tax, corporate income tax and property tax matters, both advising those clients and handling audits, administrative appeals, and litigation for them.  Read  more information on Steptoe's tax practice