Daily Tax Update - August 26, 2011: OECD Names New Transfer Pricing Leader

OECD NAMES NEW TRANSFER PRICING LEADER: Former US Treasury Deputy International Tax Counsel Joseph Andrus has been appointed Head of the OECD Transfer Pricing Unit, replacing departing head Caroline Silberztein. Andrus has recently served as a consultant to the CTPA on a number of significant transfer pricing issues, and assumes the position effective October 1.

IRS UPDATES FAQ ON SECOND OFFSHORE VOLUNTARY DISCLOSURE INITIATIVE: The IRS has updated a list of frequently asked questions on the 2011 offshore voluntary disclosure initiative, updating question 51.2 to correct an error in example 4 regarding the computation of the foreign bank account report penalty outside the initiative.

MISCELLANEOUS GUIDANCE RELEASED:

Notice 2011-71 provides guidance under section 6050W of the Internal Revenue Code regarding the documentation and reporting obligations of payment settlement entities that are United States payors making payment outside the United States to an offshore account.

Revenue Procedure 2011-42 provides taxpayers with guidance regarding the use and evaluation of statistical samples and sampling estimates. For Revenue Procedure 2011-42 the OTP contact is Eric Lucas.

Revenue Procedure 2011-43 provides a safe harbor method of accounting that taxpayers may use to determine whether expenditures to maintain, replace, or improve electric transmission and distribution property must be capitalized under ยง 263(a) of the Internal Revenue Code. The revenue procedure also provides procedures for obtaining automatic consent to change to the safe harbor method of accounting. For Revenue Procedure 2011-43, the OTP contact is Brandon Carlton.

INTERNAL REVENUE SERVICE - CIRCULAR 230 DISCLOSURE:
As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any plan or arrangement addressed herein.

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