Daily Tax Update - November 22, 2013: IRS Issues Proposed Revisions of Procedures for Requesting Assistance From US Competent Authority and Filing APAs

IRS ISSUES PROPOSED REVISIONS OF PROCEDURES FOR REQUESTING ASSISTANCE FROM U.S. COMPETENT AUTHORITY AND  FILING APAs.

Notice 2013-78 contains proposed guidance on requesting assistance from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement program and the Treaty Assistance and Interpretation Team, under the provisions of U.S. tax treaties.  The proposed revenue procedure would update and supersede Rev. Proc. 2006-54.

Notice 2013-79 contains proposed guidance and instructions on APAs and guidance and information on the IRS’s administration of APAs.  The proposed revenue procedure would substantially restate Rev. Proc. 2006-9 to improve clarity, readability, and organization.  The proposed revenue procedure also would reflect structural changes undertaken by the IRS since 2006, including the establishment of the Large Business & International Division, the realignment and consolidation of IRS transfer pricing resources under the Director, Transfer Pricing Operations, and the creation of the Advance Pricing and Mutual Agreement Program, the office responsible for evaluating, executing, and administering APAs on behalf of the IRS. 

TAX BILLS INTRODUCED NOVEMBER 21:

1. [113rd] H.R.3581 : To amend the Internal Revenue Code of 1986 to clarify the employment tax treatment and reporting of wages paid by professional employer organization, and for other purposes.

Sponsor: Rep Brady, Kevin [TX-8] (introduced 11/21/2013)      Cosponsors (1) 
Committees: House Ways and Means 
Latest Major Action: 11/21/2013 Referred to House committee. Status: Referred to the House Committee on Ways and Means.


2. [113rd] H.R.3586 : To amend the Internal Revenue Code of 1986 to provide a credit and a deduction for small political contributions.
Sponsor: Rep Petri, Thomas E. [WI-6] (introduced 11/21/2013)      Cosponsors (None) 
Committees: House Ways and Means 
Latest Major Action: 11/21/2013 Referred to House committee. Status: Referred to the House Committee on Ways and Means.


3. [113rd] S.1772 : A bill to amend the Internal Revenue Code of 1986 to expand tax-free distributions from individual retirement accounts for charitable purposes.
Sponsor: Sen Schumer, Charles E. [NY] (introduced 11/21/2013)      Cosponsors (5) 
Committees: Senate Finance 
Latest Major Action: 11/21/2013 Referred to Senate committee. Status: Read twice and referred to the Committee on Finance.