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This index is arranged by source and type of various government and external documents. Use the buttons above to view all listed documents at once or click on the appropriate headings below to browse through the listings.

Administrative (IRS and Treasury) Materials

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• Treasury Decisions/Final Regulations
  • T.D. 9571: Temporary regulations on allocation and apportionment of interest expense (TNF 2012-19, see also REG-113903-10)
  • T.D. 9572: Regulatory guidance for nonresident aliens and foreign corporations holding notional principal contracts that are dividend equivalents from U.S. sources (TNF 2012-31, see also REG-120282-10)
  • T.D. 9572: Application of specified notional principal contract rules extended to 2014 (TNF 2012-405)
  • T.D. 9573: Final regulations under section 104(a)(2) concerning exclusion of payments received for personal injuries or illness (TNF 2012-32)
  • T.D. 9574: Regulations authorizing IRS procedures for exemption from tax for qualified nonprofit health insurance issuers (TNF 2012-71, see also REG-135071-11)
  • T.D. 9576: Text of regulations relating to foreign income tax for purposes of foreign tax credits (TNF 2012-85, see also T.D. 9577 and REG-132736-11)
  • T.D. 9576: Final regulations on determining who is considered the taxpayer for purposes of section 901 (TNF 2012-86)
  • T.D. 9577: Text of regulations relating to foreign income tax for purposes of foreign tax credits (TNF 2012-85, see also T.D. 9576 and REG-132736-11)
  • T.D. 9577: Final regulations on determining who is considered the taxpayer for purposes of section 901 (TNF 2012-86)
  • T.D. 9577: Temporary and proposed foreign tax credit splitter regulations (TNF 2012-87, see also REG-132736-11)
  • T.D. 9578: Final regulations concerning group health plans and health insurance coverage of preventive services (TNF 2012-89)
  • T.D. 9579: Final regulations on withholding tax issues and tax treatment of “fails charges” paid for failure to deliver U.S. Treasury securities (TNF 2012-101)
  • T.D. 9582: Final regulations on income ordering rules for estates and trusts—specifically for charitable lead trusts (TNF 2012-196)
  • T.D. 9583: Final regulations on when to take into account a loss on the sale of property between members of a controlled group (TNF 2012-194)
  • T.D. 9584: Final regulations on reporting of deposit interest paid to nonresident aliens (TNF 2012-202, see also Rev. Proc. 2012-24)
  • T.D. 9585: Final regulations on cross-border stock transfers (TNF 2012-212)
  • T.D. 9586: Withdrawal of regulations on 3% withholding on payments made by government entities (TNF 2012-214, see also REG-151687-10)
  • T.D. 9587: Final regulations concerning the low-income housing tax credit; IRS guidance on limitations period in connection with disposals of low-income housing building (TNF 2012-226, see also Rev. Proc. 2012-27)
  • T.D. 9588: Final regulations on allocating prepaid qualified mortgage insurance premiums as residential interest (TNF 2012-229)
  • T.D. 9589: Regulations provide exception to “United States property” for upfront payments on certain notional principal contracts (TNF 2012-238, see also REG-107548-11)
  • T.D. 9590: Final regulations on health insurance premium tax credit (TNF 2012-249)
  • T.D. 9591: Final regulations under section 7874 concerning options; new temporary regulations regarding substantial business activities in a foreign country (TNF 2012-282, see also T.D. 9592 and REG-107889-12)
  • T.D. 9592: Final regulations under section 7874 concerning options; new temporary regulations regarding substantial business activities in a foreign country (TNF 2012-282, see also T.D. 9591 and REG-107889-12)
  • T.D. 9593: Regulations on electing portability of a deceased spousal unused exclusion amount (TNF 2012-290, see also REG-141832-11)
  • T.D. 9594: Final consolidated return regulations on election to treat liquidation of target, followed by a recontribution to a new target, as a cross-chain reorganization (TNF 2012-297)
  • T.D. 9595: Final regulations on overall foreign losses and overall domestic losses (TNF 2012-303)
  • T.D. 9596: Disregarded entities providing indoor tanning services are regarded for excise tax purposes under new regulations (TNF 2012-306, see also REG-122570-11)
  • T.D. 9597: Final regulations on disallowance rules for entertainment use of aircraft (TNF 2012-363)
  • T.D. 9598: Regulations provide multiple hedges are deemed sold on disposal of terminated hedge (TNF 2012-417, see also REG-138489-09)
  • T.D. 9599: Final regulations—what causes property to be “publicly traded” for issue-price purposes (TNF 2012-432)
  • T.D. 9600: Final regulations expand new markets tax credits to encourage investment in low-income communities (TNF 2012-454)
• Proposed Regulations
  • REG-100276-97: Proposed FASIT regulations are withdrawn (TNF 2012-289)
  • REG-126770-06: Proposed regulations prohibit negative amounts under simplified methods of accounting; provide new modified simplified production method (TNF 2012-411)
  • REG-138367-06: Treasury proposes to modify rules under Circular 230, to eliminate covered opinions rules (TNF 2012-437)
  • REG-101812-07: Proposed regulations on reimbursed entertainment expenses (TNF 2012-364)
  • REG-134042-07: Proposed regulations on basis of indebtedness of S corporations to their shareholders (TNF 2012-284)
  • REG-140668-07: Proposed regulations on application of section 172(h) to CERTs involving consolidated groups (TNF 2012-436)
  • REG-142561-07: Proposed regulations on agent’s identity, authority for a consolidated group (TNF 2012-266)
  • REG-139991-08: Proposed regulations on treatment of built-in gain of C corporation property transferred to RIC or REIT (TNF 2012-197)
  • REG-153627-08: Proposed regulations on employee benefit plans (TNF 2012-299, see also REG-113738-12)
  • REG-138489-09: Regulations provide multiple hedges are deemed sold on disposal of terminated hedge (TNF 2012-417, see also T.D. 9598)
  • REG-141075-09: Proposed regulations on property transferred in connection with the performances of services under section 83 (TNF 2012-264)
  • REG-110980-10: Proposed regulations to make it simpler and easier for benefit plans to offer combination of single-sum payment and annuity (TNF 2012-58)
  • REG-113770-10: Proposed regulations on medical device excise tax (TNF 2012-66)
  • REG-113770-10: Highlights of the proposed regulations on medical device excise tax (TNF 2012-72)
  • REG-113903-10: Temporary regulations on allocation and apportionment of interest expense (TNF 2012-19, see also T.D. 9571)
  • REG-120282-10: Regulatory guidance for nonresident aliens and foreign corporations holding notional principal contracts that are dividend equivalents from U.S. sources (TNF 2012-31, see also T.D. 9572)
  • REG-121647-10: FATCA proposed regulations are issued (TNF 2012-80)
  • REG-121647-10: Initial impressions of provisions under the FATCA proposed regulations (TNF 2012-82)
  • REG-135491-10: Proposed regulations would require EIN owners to update responsible person information (TNF 2012-141)
  • REG-151687-10: Withdrawal of regulations on 3% withholding on payments made by government entities (TNF 2012-214, see also T.D. 9586)
  • REG-107548-11: Regulations provide exception to “United States property” for upfront payments on certain notional principal contracts (TNF 2012-238, see also T.D. 9589)
  • REG-115809-11: Proposed regulations on minimum distribution rules for longevity annuity contracts purchased under certain benefit plans (TNF 2012-59)
  • REG-119632-11: Disclosure of return information for eligibility under health insurance affordability programs; request for information on stop loss insurance (TNF 2012-222)
  • REG-122570-11: Disregarded entities providing indoor tanning services are regarded for excise tax purposes under new regulations (TNF 2012-306, see also T.D. 9596)
  • REG-132736-11: Text of regulations relating to foreign income tax for purposes of foreign tax credits (TNF 2012-85, see also T.D. 9576 and T.D. 9577)
  • REG-132736-11: Temporary and proposed foreign tax credit splitter regulations (TNF 2012-87, see also T.D. 9577)
  • REG-134935-11: Proposed regulations on section 904(d) high tax “kick-out” and section 904(f)(3) overall foreign loss recapture on property dispositions (TNF 2012-307)
  • REG-135071-11: Regulations authorizing IRS procedures for exemption from tax for qualified nonprofit health insurance issuers (TNF 2012-71, see also T.D. 9574)
  • REG-136008-11: Proposed regulations on fees imposed with respect to health insurance, health plans (TNF 2012-191)
  • REG-141268-11: Proposed regulations to clarify E&P allocations in tax-free corporate transfers (TNF 2012-195)
  • REG-141832-11: Regulations on electing portability of a deceased spousal unused exclusion amount (TNF 2012-290, see also T.D. 9593)
  • REG-107889-12: Final regulations under section 7874 concerning options; new temporary regulations regarding substantial business activities in a foreign country (TNF 2012-282, see also T.D. 9591 and T.D. 9592)
  • REG-113738-12: Proposed regulations on employee benefit plans (TNF 2012-299, see also REG-153627-08)
• Revenue Rulings
  • Rev. Rul. 2012-1: IRS revenue ruling addresses the application of the recurring item exception to the economic performance requirement with respect to property lease and service contract (TNF 2011-603)
  • Rev. Rul. 2012-3: IRS revenue rulings concerning annuity contracts and profit-sharing and defined contribution plans (TNF 2012-60)
  • Rev. Rul. 2012-4: IRS revenue rulings concerning annuity contracts and profit-sharing and defined contribution plans (TNF 2012-60)
  • Rev. Rul. 2012-6: IRS provides state assumed interest rate schedules for insurance companies to compute their reserves for post-2010 tax years (TNF 2012-35)
  • Rev. Rul. 2012-10: IRS provides fringe benefit aircraft valuation amounts for first half of 2012 (TNF 2012-174)
  • Rev. Rul. 2012-14: IRS revenue ruling addresses income from discharge of indebtedness (TNF 2012-262)
  • Rev. Rul. 2012-17: IRS rules that REIT’s shares in money market fund are “cash items” (TNF 2012-292)
  • Rev. Rul. 2012-18: IRS guidance to employers concerning applying FICA to tip income, distributed service charges (TNF 2012-300, see also Announcement 2012-25)
  • Rev. Rul. 2012-19: IRS ruling on when dividends, dividend equivalents based on restricted stock are performance-based compensation (TNF 2012-312)
  • Rev. Rul. 2012-25: IRS addresses wage recharacterization arrangements (TNF 2012-438)
  • Rev. Rul. 2012-27: Fringe benefit aircraft valuations for second half 2012 (TNF 2012-464)
  • Rev. Rul. 2012-29: Effective date of RIC changes for purposes of section 4982 excise tax (TNF 2012-456)
• Revenue Procedures
  • Rev. Proc. 2012-1: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-1: Reminder: Changes to IRS user fees after February 4, 2012 (TNF 2012-52)
  • Rev. Proc. 2012-2: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-3: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-4: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-5: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-6: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-7: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-8: Text of annual revenue procedures for 2012; certain user fees are reduced and others increased for 2012 (TNF 2011-638)
  • Rev. Proc. 2012-11: IRS guidelines for determination letters and rulings on exempt status of qualified nonprofit health insurance issuers (TNF 2012-75)
  • Rev. Proc. 2012-13: IRS provides maximum value of employer-provided vehicles with respect to personal use in 2012 (TNF 2012-23)
  • Rev. Proc. 2012-14: IRS guidance providing safe harbor methods for REMICs to use to satisfy certain reporting obligations (TNF 2011-628, see also Notice 2012-5)
  • Rev. Proc. 2012-15: IRS updates annual revenue procedure on adequate disclosure for reducing accuracy-related penalty and for avoiding preparer penalty (TNF 2012-28)
  • Rev. Proc. 2012-17: IRS guidance allowing partnerships to provide Schedule K-1 electronically (TNF 2012-93)
  • Rev. Proc. 2012-18: IRS updates rules for ex parte communications between Appeals and other IRS function employees (TNF 2012-96)
  • Rev. Proc. 2012-19: Text of IRS guidance for changes in method of accounting under the "repair" temporary regulations (TNF 2012-132)
  • Rev. Proc. 2012-19: Transitional procedural guidance under the repair regulations—an overview (TNF 2012-138)
  • Rev. Proc. 2012-20: Text of IRS guidance for changes in method of accounting under the "repair" temporary regulations (TNF 2012-132)
  • Rev. Proc. 2012-20: Transitional procedural guidance under the repair regulations—an overview (TNF 2012-138)
  • Rev. Proc. 2012-21: IRS lists Egypt, Libya, Syria and Yemen as countries for which section 911(d)(1) eligibility requirements are waived for 2011 (TNF 2012-104)
  • Rev. Proc. 2012-23: IRS guidance, tables listing the luxury automobile depreciation limitations for 2012 (TNF 2012-121)
  • Rev. Proc. 2012-24: Final regulations on reporting of deposit interest paid to nonresident aliens (TNF 2012-202, see also T.D. 9584)
  • Rev. Proc. 2012-26: IRS provides annual HSA limitations for 2013 (TNF 2012-223)
  • Rev. Proc. 2012-27: Final regulations concerning the low-income housing tax credit; IRS guidance on limitations period in connection with disposals of low-income housing building (TNF 2012-226, see also T.D. 9587)
  • Rev. Proc. 2012-27: Taxpayers that dispose of low-income housing projects: Notify IRS of events after the disposition (TNF 2012-255)
  • Rev. Proc. 2012-28: Safe harbor for publicly traded partnership’s determination of COD income as qualifying income under section 7704(d) (TNF 2012-293)
  • Rev. Proc. 2012-29: IRS provides sample language for employees to use in making section 83(b) election for nonvested stock (TNF 2012-313)
  • Rev. Proc. 2012-31: IRS revises process, fee for requests of background file document relating to IRS National Office written determinations (TNF 2012-338)
  • Rev. Proc. 2012-32: IRS guidance on reporting agents, EFTPS program (TNF 2012-354)
  • Rev. Proc. 2012-33: IRS guidance on reporting agents, EFTPS program (TNF 2012-354)
  • Rev. Proc. 2012-39: IRS modifies accounting method change procedures — section 381(a) transactions; electric transmission company repairs; section 179D (TNF 2012-414)
  • Rev. Proc. 2012-40: Percentages for foreign insurance companies to compute minimum effectively connected net investment income for 2011 (TNF 2012-415)
  • Rev. Proc. 2012-41: Inflation adjustments for 2013 (TNF 2012-474)
• Notices
  • Notice 2012-1: IRS proposed simplified method of accounting for OID on a pool of credit card receivables (TNF 2011-597)
  • Notice 2012-2: Interim guidance pending regulations on information reporting, backup withholding for payment card and third-party network (TNF 2012-476)
  • Notice 2012-3: IRS notice on current refunding issues that refund prior issues of tax-exempt bonds in certain disaster-relief bond programs (TNF 2011-633)
  • Notice 2012-5: IRS guidance providing safe harbor methods for REMICs to use to satisfy certain reporting obligations (TNF 2011-628, see also Rev. Proc. 2012-14)
  • Notice 2012-6: IRS extends, expands transition relief for certain Puerto Rico group / retirement trusts (TNF 2011-617)
  • Notice 2012-9: IRS revises Q&A information reporting guidance to inform employees on costs of their employer-sponsored group health insurance coverage (TNF 2012-02)
  • Notice 2012-11: IRS transitional relief for section 6045B issuer returns and statements for 2011 corporate actions affecting tax basis of securities (TNF 2012-22)
  • Notice 2012-13: IRS releases guidance on how to claim expanded veterans tax credit; certification requirements streamlined (TNF 2012-83)
  • Notice 2012-14: IRS guidance when individuals eligible for medical services at Indian Health Service facility can establish HSAs (TNF 2012-55)
  • Notice 2012-15: IRS guidance under section 367 concerning certain transfers of stock to foreign corporations in exchange for property (TNF 2012-88)
  • Notice 2012-17: IRS provides answers to FAQs regarding automatic enrollment, employer shared responsibility and waiting periods (TNF 2012-84)
  • Notice 2012-20: IRS guidance on repeal of portfolio interest exemption for foreign-targeted bearer bonds (TNF 2012-131)
  • Notice 2012-21: Extension of time to file estate tax return solely to elect portability of a deceased spousal unused exclusion amount (TNF 2012-100)
  • Notice 2012-22: IRS provides an additional set of energy savings percentages relating to energy-efficient commercial building property (TNF 2012-114)
  • Notice 2012-23: IRS provides Q&As on income tax issues relating to ARRA section 1603 cash payments made for specified energy property (TNF 2012-137)
  • Notice 2012-25: IRS request for recommendations of items to be included in guidance priority list for 2012-2013 (TNF 2012-133)
  • Notice 2012-26: IRS re-issues guidance providing additional alternative energy savings deduction percentages for energy efficient commercial buildings (TNF 2012-206)
  • Notice 2012-27: IRS guidance on new fuel excise tax for fractional program aircraft (TNF 2012-177)
  • Notice 2012-30: Nonconventional source fuel credit, inflation adjustment factor, and reference price for coke and coke gas for 2011 (TNF 2012-185)
  • Notice 2012-31: IRS guidance on employer-sponsored health plans, and reporting requirements for health insurance and health plans (TNF 2012-221)
  • Notice 2012-32: IRS guidance on employer-sponsored health plans, and reporting requirements for health insurance and health plans (TNF 2012-221)
  • Notice 2012-33: IRS guidance on employer-sponsored health plans, and reporting requirements for health insurance and health plans (TNF 2012-221)
  • Notice 2012-34: IRS delays effective date for basis reporting by securities brokers for debt instruments and options (TNF 2012-227)
  • Notice 2012-38: IRS requests comments on guidance on the use of smartcards for qualified transportation fringe benefits (TNF 2012-260)
  • Notice 2012-39: IRS guidance on outbound asset reorganizations to address certain repatriation issues; regulations to be issued (TNF 2012-334)
  • Notice 2012-39: KPMG analysis: Notice 2012-39 targets repatriation transactions involving outbound transfers of intangible property in certain asset reorganizations (TNF 2012-426)
  • Notice 2012-40: IRS guidance on effective date of $2,500 limit on salary reduction contributions to health FSAs (TNF 2012-268)
  • Notice 2012-41: IRS again extends time for civilian spouses of military service members to pay tax (TNF 2012-276)
  • Notice 2012-42: Inflation adjustment factor for 2012 for section 45Q credit for carbon dioxide sequestration (TNF 2012-280)
  • Notice 2012-44: IRS provides Q&As on qualified energy conservation bonds (TNF 2012-311)
  • Notice 2012-45: IRS guidance on tax treatment of income from government bonds under PFIC rules (TNF 2012-317)
  • Notice 2012-46: Notice requirements for funding-related benefit limits in single-employer defined benefit plans (TNF 2012-346)
  • Notice 2012-48: IRS guidance on allocations of Indian tribal economic development bonds (TNF 2012-337)
  • Notice 2012-55: IRS guidance on rates that apply to adjust certain pension funding (TNF 2012-389)
  • Notice 2012-58: Safe harbor for determining full-time employees under health care law’s “shared employer responsibility” (TNF 2012-465)
  • Notice 2012-60: IRS notice concerning taxation of settlement payments to Indian tribes (TNF 2012-418)
  • Notice 2012-61: IRS provides Q&As on pension funding stabilization (TNF 2012-430)
  • Notice 2012-63: IRS notice - 2012-2013 per diem rates for substantiation of employee lodging, meals, incidental expenses (TNF 2012-455)
• Announcements
  • Announcement 2012-3: IRS extends deadline to submit on-cycle applications for opinion, advisory letters for pre-approved defined contribution plans (TNF 2011-625)
  • Announcement 2012-14: IRS closing agreement program with respect to certain reallocations of student loan bonds (TNF 2012-155)
  • Announcement 2012-16: Taxpayers have until July 27 to request telephone excise tax refunds (TNF 2012-181)
  • Announcement 2012-16: Federal district court prospectively vacates IRS notice on telephone excise tax refunds (TNF 2012-189)
  • Announcement 2012-25: IRS guidance to employers concerning applying FICA to tip income, distributed service charges (TNF 2012-300, see also Rev. Rul. 2012-18)
  • Announcement 2012-26: Competent authority agreement on eligibility of Dutch fund for treaty-reduced withholding tax rates (TNF 2012-319)
  • Announcement 2012-30: Competent authority agreements regarding Belgian municipal taxes, and with Canada on attribution of profits to permanent establishments (TNF 2012-391)
  • Announcement 2012-31: Competent authority agreements regarding Belgian municipal taxes, and with Canada on attribution of profits to permanent establishments (TNF 2012-391)
  • Announcement 2012-42: FATCA timelines for due diligence, other requirements (TNF 2012-480)
• Other IRS Releases
  • IR-2012-1: Due date for filing 2011 individual income tax returns (and paying amounts of tax due) is April 17, 2012 (TNF 2012-04)
  • IR-2012-5: IRS reopens offshore voluntary disclosure program; future guidance to be issued for residents of U.S. possessions (TNF 2012-08)
  • IR-2012-38: IRS revises procedures for APA and Competent Authority requests (TNF 2012-169)
  • IR-2012-64: IRS announces long-awaited details on open-ended offshore voluntary disclosure program (TNF 2012-314)
  • IR-2012-65: IRS initiative for U.S. citizens living abroad, and persons having foreign pension fund accounts (TNF 2012-315)
  • IR-2012-70: IRS provides relief for taxpayers affected by Hurricane Isaac (TNF 2012-416)
  • IR-2012-70: Expanded lists of Louisiana, Mississippi areas affected by Hurricane Isaac and eligible for tax relief (TNF 2012-433)
  • IR-2012-77: Inflation adjustments for 2013 (TNF 2012-474)
  • IR-2012-82: IRS provides tax relief to those affected by Hurricane Sandy (TNF 2012-487)
  • IR-2012-83: Return filing / payment deadlines extended to February 1, 2013, for taxpayers affected by Hurricane Sandy (TNF 2012-496)
  • IR-2012-84: Employer-provided hurricane relief can be excluded from employees’ taxable income (TNF 2012-494)
  • IR-2012-85: IRS suspends dyed diesel fuel penalty due to Hurricane Sandy (TNF 2012-495)
  • IRS announces no planned changes for Schedule M-3 for tax year 2012 (TNF 2012-03)
  • IRS Form 8937, Report of Organizational Actions Affecting Basis of Securities (TNF 2012-05)
  • IRS directives instruct examiners to discontinue examination of certain issues of taxpayers providing telecommunications services (TNF 2012-36)
  • IRS second quarter update to the 2011-2012 Priority Guidance Plan (TNF 2012-40)
  • IRS reminder of FATCA compliance requirements for foreign financial institutions / QIs (TNF 2012-42)
  • LB&I Directive: Guidance for IRS examiners on benefits and burdens of ownership analysis for contract manufacturing arrangements for section 199 purposes (TNF 2012-63)
  • New Form 8832, Entity Classification Election (TNF 2012-64)
  • IRS releases final version of Schedule UTP and instructions for 2011 Form 1120 series (TNF 2012-79)
  • IRS Chief Counsel Advice: Owner of disregarded entity may not split interest into separate classes for allocation of tax items or basis (TNF 2012-102)
  • IRS releases winter 2012 edition of Statistics of Income Bulletin (TNF 2012-120)
  • LB&I directive instructs examiners to discontinue audits of repair vs. capitalization issues (TNF 2012-148)
  • IRS Field Advice: Holding period not satisfied for dividends-received deduction purposes (TNF 2012-165)
  • Reminder: New March 2012 versions of Form 2848, Power of Attorney, and instructions (TNF 2012-176)
  • Revised instructions for Form 3115, Application for Change in Accounting Method (TNF 2012-180)
  • Reminder: Use revised instructions for Form 1128, Application to Adopt, Change, or Retain a Tax Year (TNF 2012-183)
  • 2012 inflation adjustment factors, reference prices for section 45 credit for renewable electricity, refined coal production (TNF 2012-187)
  • Competent authorities of United States, Germany clarify treatment of pension plans (TNF 2012-190)
  • IRS Field Service Advice: Application of mitigation provisions on claim for refund (TNF 2012-198)
  • IRS Field Service Advice: “All events” test is met on chargeback when wholesaler/dealer sells to end-user at prices below acquisition cost (TNF 2012-208)
  • IRS Chief Counsel Advice: Worthless stock loss on consolidated group subsidiary stock (TNF 2012-230)
  • IRS Field Service Advice: No income recognized on bankruptcy filing of guarantor of note securing a debt (TNF 2012-234)
  • IRS Chief Counsel Advice: Dissolution of California redevelopment agencies does not trigger re-issuance of bonds (TNF 2012-271)
  • IRS releases draft Form W-8BEN (TNF 2012-277)
  • Reminder to employers claiming expanded credit (WOTC) for hiring veterans—deadline is June 19, 2012 (TNF 2012-285)
  • IRS Chief Counsel Advice: Application of section 199 to certain computer software (TNF 2012-321)
  • IRS posts official draft Form W-8BEN (individual) for 2012 (TNF 2012-341)
  • LB&I directive on partial worthlessness deduction for eligible securities reported by insurance companies (TNF 2012-365)
  • Hearing set for November 9: Regulations for annual fee imposed on manufacturers and importers of branded prescription drugs (TNF 2012-375)
  • Draft PFIC reporting form signals intent to require annual reporting (TNF 2012-383)
  • IRS releases draft Form W-8IMY for reporting FATCA information in 2012 (TNF 2012-384)
  • IRS requests comments on future FATCA individual identification number form, FATCA registration form (TNF 2012-385)
  • IRS discontinues “tiered issue” process to manage LB&I issues; new system is being established to provide uniform guidance (TNF 2012-390)
  • Insurance company ceding 100% risk not entitled to unearned premium reserve (TNF 2012-412)
  • Tax treatment of assets held by life insurance company in separate accounts after restructuring (TNF 2012-413)
  • Schedule UTP—reminder of reduced asset threshold of $50 million for 2012 (TNF 2012-442)
  • Excise tax registration form revised to include taxable medical devices (TNF 2012-457)
  • Instructions for Form 1099-CAP (2013) (TNF 2012-460)
  • IRS Chief Counsel Advice - Electronic submissions of Form W-8 (TNF 2012-484)
  • IRS Chief Counsel Advice - Use of Build America Bond proceeds (TNF 2012-485)
  • IRS Chief Counsel Advice on consolidated return rules (TNF 2012-486)
  • States offering tax relief to taxpayers affected by Hurricane Sandy (TNF 2012-488)
  • More states provide tax relief relating to Hurricane Sandy (TNF 2012-490)
  • Additional state tax relief relating to “Superstorm Sandy” (TNF 2012-492)
  • Update of state tax hurricane-related relief (TNF 2012-497)
• Treasury
  • Treasury further extends the FBAR filing deadline for certain individuals with signature authority to June 30, 2013 (TNF 2012-94)
  • FATCA cooperation agreements with Japan, Switzerland (TNF 2012-304)
  • Model inter-governmental agreement for foreign financial institutions to use in implementing FATCA reporting requirements (TNF 2012-351)
  • Preliminary analysis of model intergovernmental agreement alternative to FATCA regime (TNF 2012-355)
  • Treasury issues list of countries that require cooperation with an international boycott (TNF 2012-386)
  • Reminder: 1603 Treasury grant program—application deadline fast approaching (TNF 2012-419)
  • United States, United Kingdom sign bilateral FATCA agreement (TNF 2012-439)
  • OMB report indicates potential 7.6% cut to section 1603 grant payments in FY 2013 (TNF 2012-445)

Legislative Materials

Expand All Legislative Materials
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• House
  • H.R. 8: Legislative Update: House to consider tax-cut bill (TNF 2012-367)
  • H.R. 9: Legislative Update: House Ways and Means, Senate Democrats propose alternative business tax cuts (TNF 2012-168)
  • H.R. 9: Legislative Update: House passes temporary cut in tax on domestic income of qualified small businesses (TNF 2012-205)
  • H.R. 436: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • H.R. 436: Legislative Update: House passes consolidated health-related tax bill (TNF 2012-281)
  • H.R. 658: Legislative Update: Conferees sign off on FAA reauthorization (TNF 2012-62)
  • H.R. 658: Legislative Update: House passes FAA conference report; Ways and Means reports out the highway bill (TNF 2012-65)
  • H.R. 658: New FAA law includes changes to aviation and fuel taxes on fractional aircraft flights, ends small jet aircraft exemption from aviation taxes (TNF 2012-95)
  • H.R. 1004: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • H.R. 1173: Legislative Update: JCT description of bill to repeal CLASS program (TNF 2012-21)
  • H.R. 1173: Legislative Update: Ways and Means approves bill repealing health care “CLASS Act” (TNF 2012-29)
  • H.R. 1173: Legislative Update: House passes bill repealing “CLASS Act” for long-term insurance (TNF 2012-57)
  • H.R. 1864: Legislative Update: House passes bill limiting multi-state taxation (TNF 2012-244)
  • H.R. 3630: Legislative Update: Conferees agree to payroll tax extension, unemployment benefits, “doc fix” (TNF 2012-99)
  • H.R. 3630: Legislative Update: Congress passes payroll-tax cut legislation; includes provision eliminating corporate estimated tax safe harbor shifts (TNF 2012-103)
  • H.R. 3800: Legislative Update: House passes two-week extension of excise taxes funding aviation (TNF 2012-37)
  • H.R. 3800: Legislative Update: Bill providing two-week extension of excise taxes funding aviation is received by White House (TNF 2012-49)
  • H.R. 3800: Two-week extension of excise taxes funding aviation is enacted (TNF 2012-54)
  • H.R. 3606: Legislation to encourage public capital raising in the United States by companies with less than $1 billion in revenue (TNF 2012-173)
  • H.R. 3864: Legislative Update: Ways and Means Committee sets markup of highway bill (TNF 2012-61)
  • H.R. 3864: Legislative Update: House passes FAA conference report; Ways and Means reports out the highway bill (TNF 2012-65)
  • H.R. 4239: Legislative Update: House, Senate on separate tracks on energy, highway bills (TNF 2012-167)
  • H.R. 4281: Legislative Update: Congress clears three-month extension of highway-related excise taxes (TNF 2012-171)
  • H.R. 4348: Legislative Update: House passes highway extension, intends conference with Senate (TNF 2012-203)
  • H.R. 5652: Legislative Update: House passes bill replacing defense cuts with domestic-spending reductions (TNF 2012-237)
  • H.R. 5842: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • H.R. 5858: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • Legislative Update: Expiration of the research credit and other “business extenders” (TNF 2012-10)
  • Legislative Update: Obama budget would tax dividends as ordinary income for high-income taxpayers (TNF 2012-92)
  • Legislative Update: Energy-related proposals in administration’s FY 2013 budget (TNF 2012-98)
  • Legislative Update: Budget Chairman Ryan unveils House budget resolution with reduced tax rates (TNF 2012-156)
  • Legislative Update: House Budget Committee approves FY2013 budget resolution (TNF 2012-159)
  • Legislative Update: House passes budget resolution on party-line vote; Senate Republicans block oil-tax bill (TNF 2012-172)
  • Legislative Update: Ways and Means to mark up reconciliation (TNF 2012-201)
  • Reminder: Highway-related excise taxes are extended and continue to apply (TNF 2012-333)
  • Legislative Update: House sets votes on competing tax-cut bills (TNF 2012-362)
  • Energy sustainability – Year-end update (TNF 2012-479)
  • Individual tax rates - Year-end update (TNF 2012-482)
  • Backup withholding rate - Year-end update (TNF 2012-489)
• Senate
  • H.R. 658: Legislative Update: Senate passes FAA conference report, sending legislation to the White House (TNF 2012-76)
  • H.R. 3800: Legislative Update: Senate passes two-week extension of excise taxes funding aviation, sending bill to White House (TNF 2012-45)
  • S. 1813: Legislative Update: Finance Committee sets highway markup (TNF 2012-74)
  • S. 1813: Legislative Update: Senate tax title on highway bill introduced (TNF 2012-97)
  • S. 1813: Legislative Update: JCT estimates of pending Senate highway bill (TNF 2012-128)
  • S. 1813: Legislative Update: Senate begins voting on amendments to highway bill (TNF 2012-135)
  • S. 1813: Legislative Update: Senate passes highway bill; JCT provides revenue estimate (TNF 2012-146)
  • S. 2204: Legislative Update: House passes budget resolution on party-line vote; Senate Republicans block oil-tax bill (TNF 2012-172)
  • S. 2343: Legislative Update: Senate Democrats offer student loan interest bill with S corporation employment tax revenue offset (TNF 2012-219)
  • S. 3412: Legislative Update: Senate passes Democrats’ tax bill (TNF 2012-350)
  • Legislative Update: Finance Committee holds hearing on extending expired tax provisions (TNF 2012-51)
  • Legislative Update: Senate Democrats propose “Buffett rule” minimum tax on high-income individuals (TNF 2012-56)
  • Legislative Update: Finance Committee considers revenue provisions of Senate highway bill (TNF 2012-78)
  • Legislative Update: Senate starts consideration of Democratic jobs bill (TNF 2012-331)
  • Legislative Update: Reid unveils Democrats’ tax bill allowing high-income tax cuts to lapse (TNF 2012-339)
  • Legislative Update: Congress prepares for tax-cut votes (TNF 2012-349)
  • Legislative Update: Senate Finance leaders’ agreement on extenders (TNF 2012-366)
  • Legislative Update: Finance Committee approves extenders legislation (TNF 2012-369)
  • Legislative Update: Production tax credit for wind included in Finance Committee’s tax extender package (TNF 2012-371)
  • Legislative Update: Finance Committee completes report on extenders bill (TNF 2012-403)
  • Legislative Update: Finance Committee’s extenders bill drops 10 provisions (TNF 2012-421)
  • Legislative Update: Investigations subcommittee examines multinationals’ use of offshore entities (TNF 2012-446)
  • Legislative Update: JCT estimates costs of a 4% tax-rate cut (TNF 2012-471)
• Joint Committee on Taxation
  • JCS-1-12: Estimates of Federal Tax Expenditures for Fiscal Years 2011-2015 : Legislative Update: JCT estimates of federal tax expenditures (FYs 2011-2015) (TNF 2012-26)
  • JCS-2-12: Description of Revenue Provisions Contained in the President’s Fiscal Year 2013 Budget Proposal: Legislative Update: JCT description of president’s tax proposals for FY 2013 (TNF 2012-296)
  • JCX-1-12: List of Expiring Federal Tax Provisions 2011-2022: Legislative Update: JCT provides annual list of expiring federal tax provisions (TNF 2012-07)
  • JCX-2-12: Comparison of Revenue Provisions of H.R. 3630 as Passed by the House (“Middle Class Tax Relief and Job Creation Act of 2011”) and as Amended by the Senate (“Temporary Payroll Tax Cut Continuation Act of 2011”): Legislative Update: JCT report on differences in House and Senate bills to extend payroll-tax reduction (TNF 2012-15)
  • JCX-3-12: Legislative Update: JCT report on differences in House and Senate bills to extend payroll-tax reduction (TNF 2012-15)
  • JCX-5-12: Description of Select Provisions Related to the Harbor Maintenance Tax and Trust Fund, and Certain Controlled Foreign Corporation Base Company Shipping Income Provisions: Legislative Update: JCT describes proposals concerning harbor maintenance tax and CFC foreign-base company shipping income (TNF 2012-47)
  • JCX-7-12: Description of H.R. 3864, the American Energy and Infrastructure Jobs Financing Act of 2012: Legislative Update: Ways and Means Committee sets markup of highway bill (TNF 2012-61)
  • JCX-8-12: Legislative Update: Ways and Means Committee sets markup of highway bill (TNF 2012-61)
  • JCX-9-12: Description of the Chairman’s Mark of S. _____, The “Highway Investment, Job Creation and Economic Growth Act of 2012”: Legislative Update: Finance Committee sets highway markup (TNF 2012-74)
  • JCX-10-12: Legislative Update: Finance Committee sets highway markup (TNF 2012-74)
  • JCX-11-12: Description of the Chairman’s Modification to the Proposals of the “Highway Investment Job Creation and Economic Growth Act of 2012”: Legislative Update: Finance Committee considers revenue provisions of Senate highway bill (TNF 2012-78)
  • JCX-12-12: Legislative Update: Finance Committee considers revenue provisions of Senate highway bill (TNF 2012-78)
  • JCX-13-12: Present Law and Background Relating to the Interaction of Federal Income Tax Rules and Financial Accounting Rules: Legislative Update: JCT description of interaction of federal income tax rules and financial accounting rules (TNF 2012-77)
  • JCX-14-12: Legislative Update: Finance Committee considers revenue provisions of Senate highway bill (TNF 2012-78)
  • JCX-17-12: Legislative Update: Conferees agree to payroll tax extension, unemployment benefits, “doc fix” (TNF 2012-99)
  • JCX-18-12: Overview of the Federal Tax System as in Effect for 2012: Legislative Update: JCT overview of federal tax system for 2012 (TNF 2012-115)
  • JCX-19-12: Background and Present Law Relating to Cost Recovery and Domestic Production Activities: Legislative Update: JCT description of tax treatment of cost recovery and domestic production activities (TNF 2012-117)
  • JCX-20-12: Selected Issues Relating to Choice of Business Entity: Legislative Update: JCT examines issues concerning taxpayers’ choices of business entities (TNF 2012-127)
  • JCX-21-12: Legislative Update: JCT estimates of pending Senate highway bill (TNF 2012-128)
  • JCX-22-12: Legislative Update: JCT estimates of pending Senate highway bill (TNF 2012-128)
  • JCX-24-12: Errata for JCX-20-12, Selected Issues Relating to Choice of Business Entity: Legislative Update: JCT examines issues concerning taxpayers’ choices of business entities (TNF 2012-127)
  • JCX-25-12: Legislative Update: Senate passes highway bill; JCT provides revenue estimate (TNF 2012-146)
  • JCX-26-12: Legislative Update: Senate passes highway bill; JCT provides revenue estimate (TNF 2012-146)
  • JCX-27-12: Legislative Update: JCT revenue estimate of provisions in Obama administration’s FY 2013 budget (TNF 2012-147)
  • JCX-28-12: Present Law and Analysis of Energy-Related Tax Expenditures: Legislative Update: JCT description and estimate of renewable energy tax incentives (TNF 2012-161)
  • JCX-29-12: Estimated Budget Effects of S. 2204, the “Repeal Big Oil Tax Subsidies Act” Scheduled for Consideration on the Senate Floor on March 26, 2012: Legislative Update: JCT description and estimate of renewable energy tax incentives (TNF 2012-161)
  • JCX-30-12: Small Business Tax Cut Act: Legislative Update: House Ways and Means, Senate Democrats propose alternative business tax cuts (TNF 2012-168)
  • JCX-31-12: Description of an amendment in the nature of a substitute to the provisions of H.R. 9, the “Small Business Tax Cut Act": Legislative Update: House Ways and Means, Senate Democrats propose alternative business tax cuts (TNF 2012-168)
  • JCX-32-12: Present Law and Background Relating to the Tax Treatment of Retirement Savings: Legislative Update: JCT report on retirement savings taxation (TNF 2012-193)
  • JCX-34-12: Description of budget reconciliation legislative recommendations relating to federally-subsidized health insurance overpayments: Legislative Update: Ways and Means to mark up reconciliation (TNF 2012-201)
  • JCX-35-12: Description of the budget reconciliation legislative recommendations relating to social security number requirements for the refundable portion of the child tax credit: Legislative Update: Ways and Means to mark up reconciliation (TNF 2012-201)
  • JCX-39-12: Legislative Background of Selected Federal Tax Provisions Scheduled to Expire in 2011 or 2012: Legislative Update: JCT describes tax extenders’ provisions for Ways and Means subcommittee hearing (TNF 2012-218)
  • JCX-41-12: Federal Tax Law and Issues Related to the United States Territories: Legislative Update: JCT report on federal taxation of U.S. territories (TNF 2012-243)
  • JCX-43-12: Legislative Update: Joint Committee on Taxation releases estimates of House, Senate highway bills (TNF 2012-265)
  • JCX-44-12: Legislative Update: Joint Committee on Taxation releases estimates of House, Senate highway bills (TNF 2012-265)
  • JCX-45-12: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-46-12: Description of H.R.5842, the “Restoring Access to Medication Act”: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-47-12: Description of the Provisions of H.R. 5858, A Bill to Amend the Internal Revenue Code of 1986 to Improve Health Savings Accounts and for Other Purposes: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-49-12: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-50-12: Description of an amendment in the nature of a substitute to the provisions of H.R. 436, the "Protect Medical Innovation Act of 2011": Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-51-12: Description of an amendment in the nature of a substitute to the provisions of H.R. 5842, The “Restoring Access To Medication Act”: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-53-12: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-54-12: Description of an amendment in the nature of a substitute to the provisions of H.R. 1004, The “Medical FSA Improvement Act of 2011”: Legislative Update: Ways and Means sets markup of health-related tax bills (TNF 2012-267)
  • JCX-55-12: Legislative Update: House passes consolidated health-related tax bill (TNF 2012-281)
  • JCX-57-12 R: Legislative Update: Conference report on highway bill (TNF 2012-318)
  • JCX-58-12: Legislative Update: Conference report on highway bill (TNF 2012-318)
  • JCX-59-12: Legislative Update: Senate starts consideration of Democratic jobs bill (TNF 2012-331)
  • JCX-61-12: Background and Present Law Relating to Manufacturing Activities Within the United States: Legislative Update: JCT report on taxation of manufacturing sector (TNF 2012-344)
  • JCX-63-12: “Job Protection and Recession Prevention Act of 2012” Scheduled for Consideration by the House of Representatives: Legislative Update: Congress prepares for tax-cut votes (TNF 2012-349)
  • JCX-64-12: Legislative Update: Congress prepares for tax-cut votes (TNF 2012-349)
  • JCX-65-12: Legislative Update: Senate passes Democrats’ tax bill (TNF 2012-350)
  • JCX-66-12: Selected Issues Relating to Choice of Business Entity: Legislative Update: JCT report on tax issues and choice of business entity (TNF 2012-359)
  • JCX-67-12: Description of the Family and Business Tax Cut Certainty Act of 2012: Legislative Update: Senate Finance leaders’ agreement on extenders (TNF 2012-366)
  • JCX-68-12: Legislative Update: Senate Finance leaders’ agreement on extenders (TNF 2012-366)
  • JCX-69-12: Description of the Chairman’s Modification to the Proposals of the “Family and Business Tax Cut Certainty Act of 2012”: Legislative Update: Finance Committee approves extenders legislation (TNF 2012-369)
  • JCX-70-12: Legislative Update: Finance Committee approves extenders legislation (TNF 2012-369)
  • JCX-72-12: Present Law and Background Information Related to the Taxation of Capital Gains: Legislative Update: JCT report on capital gains taxation (TNF 2012-440)
  • JCX-73-12: Legislative Update: JCT revenue estimates on pending bills (TNF 2012-443)
  • JCX-74-12: Legislative Update: JCT revenue estimates on pending bills (TNF 2012-443)
  • JCX-75-12: Legislative Update: JCT revenue estimates on pending bills (TNF 2012-443)

Judicial Materials

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• Court Decisions
  • Alpha I v. United States: Federal Circuit reverses claims court, finds identity of partners to be made at partnership level (TNF 2012-291)
  • American Financial Group v. United States: Sixth Circuit affirms insurance company’s $59 million refund arising from accounting changes (TNF 2012-231)
  • Amerisouth XXXII, Ltd. v. Commissioner: Tax Court: Apartment structural components to be depreciated over the life of the buildings, not as separate items of tangible personal property (TNF 2012-140)
  • Bausch & Lomb, Inc. v. Commissioner: Tax Court: Deficiency notice held invalid because decision in related partnership proceeding was not final (TNF 2012-27)
  • Beard v. Commissioner: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • Bronstein v. Commissioner: Tax Court: “Married filing separately” limits the mortgage interest deduction to $500,000 of home acquisition indebtedness (not $1 million) (TNF 2012-248)
  • Brooks v. Commissioner: Tax Court: Stockbroker is liable for income tax with respect to accrued interest on loan provided by his employer (TNF 2012-44)
  • Brown v. Commissioner: Seventh Circuit: Individual who borrowed against insurance policy is liable for income tax on its cancellation (TNF 2012-431)
  • Calloway v. Commissioner: Eleventh Circuit affirms Tax Court’s finding that “90% stock-loan program” transaction was a sale (TNF 2012-396)
  • Caltex Oil Venture v. Commissioner: Tax Court: Deduction for intangible drilling costs is disallowed under economic performance rule; no drill bit had penetrated the ground (TNF 2012-18)
  • Carlebach v. Commissioner: Tax Court: Taxpayer’s child must be U.S. citizen or resident to be claimed as dependent (TNF 2012-345)
  • Cigna Corp. v. Commissioner: Tax Court declines to decide insurance company’s tax reserve issue when IRS concedes no deficiency (TNF 2012-435)
  • City of Columbus v. Hotels.com L.P.: Sixth Circuit: Online travel companies not required to collect municipal guest taxes (TNF 2012-429)
  • Curcio v. Commissioner: Second Circuit: Life insurance payments covering only key principals not “ordinary and necessary” business expenses (TNF 2012-380)
  • Delhaize America, Inc. v. Lay: North Carolina: Appeals court finds forced combination was proper; negligence penalty applies (TNF 2012-394)
  • DeNaples v. Commissioner: Third Circuit: Installment interest excluded from income under section 103 when implicating state’s need for credit (TNF 2012-154)
  • Direct Marketing Ass’n v. Huber: Colorado: Federal district court holds that use tax reporting requirements violate Commerce Clause (TNF 2012-178)
  • Dominion Resources, Inc. v. United States: Federal Circuit holds regulations invalid under section 263A for interest incurred on property temporarily withdrawn from service (TNF 2012-270)
  • Dorrance v. United States: Federal district court rejects “zero basis” rule and declines application of the open transaction doctrine (TNF 2012-332)
  • Entergy Corp. v. Commissioner: Fifth Circuit affirms U.K. windfall tax (1997) imposed on utilities is creditable tax under section 901; disagrees with Third Circuit (TNF 2012-278)
  • Exxon Mobil Corp. v. Commissioner: Second Circuit holds interest netting is available as long as “one leg” of overlapping periods is open; Federal Circuit’s position is rejected (TNF 2012-376)
  • Gerdau Macsteel, Inc. v. Commissioner: Tax Court rejects 40% gross valuation misstatement penalty, but sustains 20% accuracy-related penalty in tax shelter case (TNF 2012-408)
  • The Gillette Co. v. Franchise Tax Board: California: Appeals court upholds taxpayer’s election to apportion income using Multistate Tax Compact (TNF 2012-353)
  • The Gillette Co. v. Franchise Tax Board: California: Appeals court issues order for rehearing and vacates Gillette decision (election to apportion income using Multistate Tax Compact) (TNF 2012-381)
  • Gillette Co. v. Franchise Tax Board: California - Appeals court again upholds election to apportion income using Multistate Tax Compact (TNF 2012-461)
  • Gillette Co. v. Franchise Tax Board: California - Franchise Tax Board guidance following Gillette decision (TNF 2012-468)
  • Grapevine Imports, Ltd. v .United States: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • Gustashaw v. Commissioner: Eleventh Circuit affirms 40% penalty in tax shelter case (TNF 2012-458)
  • Hall v. United States: U.S. Supreme Court: Capital gains tax on farm’s sale after bankruptcy petition is not dischargeable under Chapter 12 (TNF 2012-241)
  • Hartman v. United States: Federal Circuit addresses when shares are constructively received (TNF 2012-427)
  • Hewlett-Packard Co. v. Commissioner: Tax Court: Investment in foreign corporation was a loan; capital loss on exit from transaction is disallowed (TNF 2012-242)
  • Hewlett-Packard Co. v. Commissioner: Tax Court - Nonsales income included in gross receipts for calculating research credit in pre-regulation tax years (TNF 2012-452)
  • Historic Boardwalk Hall, LLC v. Commissioner: Third Circuit reverses Tax Court: Taxpayer not bona fide partner for transfer of historic rehabilitation tax credits (TNF 2012-399)
  • Historic Boardwalk Hall LLC v. Commissioner: KPMG analysis: Third Circuit’s decision on partnership transfer of historic rehabilitation tax credits (TNF 2012-428)
  • Intermountain Ins. Serv. of Vail, LLC v. Commissioner: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • Kawashima v. Holder: U.S. Supreme Court: Convictions relating to false tax returns may be basis for deportation (TNF 2012-109)
  • Kim v. Commissioner: Seventh Circuit: Individual liable for 10% additional tax for withdrawal from IRA (not from employer’s pension plan) (TNF 2012-236)
  • Maguire v. Commissioner: Tax Court: Shareholders may receive distribution from one S corporation, and contribute it to another S corporation in order to deduct losses (TNF 2012-279)
  • Mangano v. Silver: New York: Trial court invalidates MTA payroll tax (TNF 2012-402)
  • Massachusetts Mutual Life Insurance Co. v. United States: Court of Federal Claims allows insurance company’s deductions for dividend guarantees (TNF 2012-50)
  • McLaine v. Commissioner: Tax Court “reviewed opinion” addresses third-party payment of taxes owed on exercise of stock options (TNF 2012-144)
  • Meruelo v. Commissioner: Ninth Circuit affirms deficiency notice relating to passthrough loss was valid, not premature (TNF 2012-387)
  • Miccosukee Tribe of Indians of Florida v. United States: Eleventh Circuit - Indian tribe’s petitions to quash IRS summonses denied (TNF 2012-473)
  • Mulcahy, Pauritsch, Salvador & Co., Ltd. v. Commissioner: Seventh Circuit: Firm’s payments of consulting fees are reclassified as dividends; corporate income tax deficiencies upheld (TNF 2012-247)
  • Myles Lorentz, Inc. v. Commissioner: Tax Court: Taxpayer not entitled to income tax credits for its claimed off-highway business use of diesel fuel (TNF 2012-39)
  • NA General Partnership & Subsidiaries v. Commissioner: Tax Court: Advance to subsidiary was debt; interest expense deductions allowed (TNF 2012-298)
  • National Federation of Independent Business v. Sebelius: U.S. Supreme Court upholds individual mandate in health care case (TNF 2012-316)
  • Neff v. Commissioner: Tax Court determines when split-dollar life insurance arrangements were terminated (TNF 2012-398)
  • New Jersey Retail Merchants Association v. Sidamon-Eristoff: New Jersey: Discussion of Third Circuit’s decision in unclaimed property stored-value card litigation (TNF 2012-12)
  • Olive v. Commissioner: Tax Court: Medical marijuana dispensary barred from deducting expenses (TNF 2012-368)
  • Packard v. Commissioner: Tax Court addresses first-time homebuyer credit eligibility (TNF 2012-498)
  • Peco Foods, Inc. v. Commissioner: Discussion: Tax Court holds a section 1060 purchase price allocation trumps taxpayer's cost segregation study (TNF 2012-48)
  • Pepsico Puerto Rico Inc. v. Commissioner: Tax Court finds advance agreements are equity, not debt (TNF 2012-447)
  • Rawls Trading L.P. v. Commissioner: Tax Court addresses jurisdiction when FPAA is issued in tiered-partnership structure (TNF 2012-166)
  • Research Corp. v. Commissioner: Tax Court finds entity exempt from tax is not subject to 20% excise tax on amounts received on termination of pension plan (TNF 2012-118)
  • Salman Ranch, Ltd. v. Commissioner: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • Shannahan v. Internal Revenue Service: Ninth Circuit affirms IRS documents are protected from FOIA disclosure (TNF 2012-142)
  • Solleberger v. Commissioner: Ninth Circuit affirms taxpayer’s transfer of floating rate notes for cash was a sale, not a nonrecourse loan (TNF 2012-388)
  • Sophy v. Commissioner: Tax Court: Limits on acquisition and home equity indebtedness apply on a per-residence, not per-taxpayer, basis (TNF 2012-126)
  • Staples, Inc. v. Cook: Delaware: “Rebates” are found to be escheatable property (TNF 2012-81)
  • State Farm Mutual Automobile Ins. Co. v. Commissioner: Seventh Circuit: Insurance company’s bad-faith punitive damages are business losses when actually paid, not part of insurance loss reserves (TNF 2012-409)
  • Stromme v. Commissioner: Tax Court “reviewed opinion” on definition of taxpayer’s “home” under section 131 (TNF 2012-143)
  • Southwest Royalties Inc. v. Combs: Texas: State court holds oil and gas producer qualifies for manufacturing exemption (TNF 2012-213)
  • Taproot Administrative Services, Inc. v. Commissioner: Ninth Circuit: No S corporation status available when sole shareholder is custodial Roth IRA account (TNF 2012-157)
  • Thrifty Oil Co. v. Commissioner: Tax Court: Taxpayer not entitled to environmental remediation expense deductions already claimed as capital loss deductions (TNF 2012-407)
  • TIFD III-E, Inc. v. United States: Second Circuit: Foreign banks’ interest in “Castle Harbour” partnership was as secured lenders, not as capital interest; district court is reversed (TNF 2012-38)
  • Tiger Eye Trading, LLC v. Commissioner: Tax Court: Text of opinion concerning court’s jurisdiction over accuracy-related penalty in partnership-level proceedings (TNF 2012-91)
  • Trugman v. Commissioner: Tax Court: S corporation is not an “individual” eligible for first-time homebuyer tax credit (TNF 2012-257)
  • Union Carbide Corp. v. Commissioner: Second Circuit: Costs for raw materials used in testing improvements to production processes denied research credit (TNF 2012-422)
  • United States v. Home Concrete & Supply, LLC: U.S. Supreme Court: Overstatement of basis does not trigger six-year statute of limitations on assessment (TNF 2012-216)
  • United States v. Home Concrete & Supply, LLC: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • United States v. Quality Stores, Inc.: KPMG analysis: FICA tax refunds on severance pay (TNF 2012-444)
  • In re Quality Stores, Inc.: Sixth Circuit: Qualifying severance payments are not wages; FICA tax refund upheld (TNF 2012-423)
  • UTAM, Ltd. v. Commissioner: U.S. Supreme Court vacates judgments, remands cases following Home Concrete & Supply decision (TNF 2012-225)
  • Veriha v. Commissioner: Tax Court: Rental income recharacterized as nonpassive; each tractor, each trailer a separate “item of property” under passive loss regulations (TNF 2012-378)
  • Weber v. Commissioner: Tax Court: Credit elect overpayment not available when applied against section 6672 penalty assessment (TNF 2012-235)
  • Welch v. United States: Federal Circuit: IRS failed to prove timely mailing of deficiency notice with collaborating evidence when established procedures not followed (TNF 2012-250)
  • Windsor v. United States: Second Circuit - Eligibility of surviving spouse of same-sex couple for federal estate tax spousal deduction (TNF 2012-475)
  • Yarish v. Commissioner: Tax Court - Benefits in retroactively disqualified ESOP subject to tax in year of termination (TNF 2012-463)

State and Local Taxes

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• California
  • California: Appeals court upholds taxpayer’s election to apportion income using Multistate Tax Compact (TNF 2012-353)
  • California: Appeals court issues order for rehearing and vacates Gillette decision (election to apportion income using Multistate Tax Compact) (TNF 2012-381)
  • California - Franchise Tax Board guidance following Gillette decision (TNF 2012-468)
• Colorado
  • Colorado: Federal district court holds that use tax reporting requirements violate Commerce Clause (TNF 2012-178)
• Delaware
  • Delaware: “Rebates” are found to be escheatable property (TNF 2012-81)
  • Delaware and New Jersey: New legislation concerning “unclaimed property” (TNF 2012-327)
• District of Columbia
  • District of Columbia: Proposed combined reporting regulation (TNF 2012-43)
  • District of Columbia: Guidance for extensions due March 15, 2012 (TNF 2012-145)
  • District of Columbia: Revised combined reporting regulation issued (TNF 2012-424)
• Georgia
  • Georgia: New laws include changes to manufacturing exemption, energy exemption, and establish click-through nexus (TNF 2012-207)
• Illinois
  • Illinois: Retailers and the taxation of “shipping and handling” charges (TNF 2012-179)
• Michigan
  • Michigan: Unclaimed property deadline is January 31, 2012 (TNF 2012-25)
• Minnesota
  • Minnesota: Unclaimed property compliance initiative (TNF 2012-228)
• New Jersey
  • New Jersey: Discussion of Third Circuit’s decision in unclaimed property stored-value card litigation (TNF 2012-12)
  • Delaware and New Jersey: New legislation concerning “unclaimed property” (TNF 2012-327)
• New York
  • New York: Analysis of the state’s new position regarding tax treatment of unauthorized life insurers (TNF 2012-164)
  • New York: Trial court invalidates MTA payroll tax (TNF 2012-402)
• North Carolina
  • North Carolina: Appeals court finds forced combination was proper; negligence penalty applies (TNF 2012-394)
• Puerto Rico
  • Puerto Rico: Tax amnesty program to expire February 29, 2012 (TNF 2012-73)
  • Puerto Rico: Corporate groups must request identification number for each member to use in filing income tax returns for 2011 (TNF 2012-129)
  • Puerto Rico: Credit for retaining employment of certain individuals newly hired in 2010 (TNF 2012-130)
  • Puerto Rico: Temporary guidance for determining deductible expenses related to use and maintenance of automobiles (TNF 2012-149)
  • Puerto Rico: Tax amnesty is extended to June 15, 2012 (TNF 2012-217)
  • Puerto Rico: Guidelines for passthrough entities to elect treatment as partnerships or corporations (TNF 2012-302)
  • Puerto Rico: Deductible vehicle expenses (effective July 2012) are business mileage-based only (TNF 2012-325)
• Texas
  • Texas: State court holds oil and gas producer qualifies for manufacturing exemption (TNF 2012-213)
  • Texas: Franchise taxpayers can now change election to deduct COGS or compensation on amended reports (TNF 2012-287)

Other Materials

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• Defining Issues
  • Defining Issues: FASB defers requirement to present reclassification of other comprehensive income items within net income (TNF 2012-01)
  • Defining Issues: PCAOB re-proposes auditing standard on communication with audit committees (TNF 2012-06)
  • Defining Issues: SEC staff issues disclosure guidance on exposure to European sovereign debt (TNF 2012-13)
  • Defining Issues: FAF releases post-implementation review report on FIN 48 (TNF 2012-30)
  • Defining Issues: FASB and IASB revise joint revenue recognition exposure draft (TNF 2012-33)
  • Defining Issues: FASB proposes change to impairment testing of indefinite-lived intangible assets (TNF 2012-41)
  • Defining Issues: U.S. GAAP: Constituents respond to FAF proposal to create private company standards improvement council (TNF 2012-53)
  • Defining Issues: FASB and IASB reconsider views on lessee accounting (TNF 2012-119)
  • Defining Issues: PCAOB proposals address related parties and significant unusual transactions (TNF 2012-124)
  • Defining Issues: FASB adds project to define nonpublic entity as it considers private company issues (TNF 2012-134)
  • Defining Issues: PCAOB proposes to apply its requirements to auditors of brokers and dealers and establish a new auditor reporting requirement (TNF 2012-136)
  • Defining Issues: FASB’s Emerging Issues Task Force reaches three consensuses-for-exposure (TNF 2012-150)
  • Defining Issues: FASB—Questions and interpretive responses for fair value measurement (TNF 2012-162)
  • Defining Issues: FASB proposal on principal-agent considerations in consolidation evaluations (TNF 2012-184)
  • Defining Issues: FASB adds project to revisit repurchase agreements and similar transactions (TNF 2012-188)
  • Defining Issues: SEC seeks comments on JOBS Act rulemaking and provides guidance (TNF 2012-192)
  • Defining Issues: SEC provides Q&As about company disclosures under JOBS Act (TNF 2012-220)
  • Defining Issues: SEC disclosure guidance for smaller financial institutions includes policy on deferred taxes (TNF 2012-239)
  • Defining Issues: SEC issues letter on accounting for OTC derivatives under Dodd-Frank Act (TNF 2012-245)
  • Defining Issues: FASB / IASB: Constituents respond to the revised revenue recognition exposure draft (TNF 2012-246)
  • Defining Issues: FAF establishes new Private Company Council (TNF 2012-259)
  • Defining Issues: FASB and IASB discuss alternative lessee income statement measurement approaches (TNF 2012-261)
  • Defining Issues: SEC answers more questions about the JOBS Act (TNF 2012-269)
  • Defining Issues: FASB / IASB choose dividing line for lessee and lessor accounting (TNF 2012-286)
  • Defining Issues: FASB / IASB reconsider investment company accounting proposals (TNF 2012-301)
  • Defining Issues: FASB task force reaches two consensuses-for-exposure (TNF 2012-305)
  • Defining Issues: FASB / IASB: U.S. standard-setting landscape poised for significant change (TNF 2012-320)
  • Defining Issues: FASB proposes significant new disclosures about liquidity and interest rate risks (TNF 2012-326)
  • Defining Issues: FASB proposes requirements for liquidation basis of accounting; discusses next steps for going concern project (TNF 2012-329)
  • Defining Issues: FASB removes loss contingency disclosure project from its agenda (TNF 2012-330)
  • Defining Issues: SEC staff issues final report on IFRS work plan (TNF 2012-340)
  • Defining Issues: FASB / IASB substantially complete redeliberations on accounting for leases (TNF 2012-343)
  • Defining Issues: FASB requests comments on disclosure framework project (TNF 2012-347)
  • Defining Issues: FASB / IASB begin re-deliberations on proposed revenue recognition standard (TNF 2012-352)
  • Defining Issues: FASB adds optional qualitative assessment to indefinite-lived intangible asset impairment test (TNF 2012-361)
  • Defining Issues: FASB to explore an alternative impairment model for financial assets (TNF 2012-370)
  • Defining Issues: PCAOB provides information for audit committees about its inspection process (TNF 2012-373)
  • Defining Issues: FASB requests comments on private company decision-making framework (TNF 2012-374)
  • Defining Issues: FASB decides not to develop investment property entities guidance (TNF 2012-379)
  • Defining Issues: FASB proposes revision to presenting items reclassified out of “accumulated other comprehensive income” (TNF 2012-393)
  • Defining Issues: PCAOB issues new auditing standard on communications with audit committees (TNF 2012-395)
  • Defining Issues: FASB decisions on alternative impairment model for financial assets (TNF 2012-404)
  • Defining Issues: SEC issues final rule for extractive industry payments (TNF 2012-406)
  • Defining Issues: SEC final rule for disclosures about conflict minerals (TNF 2012-410)
  • Defining Issues: IASB issues hedge accounting model (TNF 2012-420)
  • Defining Issues: FASB task force reaches three final consensuses (TNF 2012-434)
  • Defining Issues: Quarterly review of accounting, financial reporting developments (TNF 2012-448)
  • Defining Issues: FASB / IASB address remaining issues, delay revised leases exposure drafts (TNF 2012-453)
  • Defining Issues: FASB / IASB - Continued re-deliberations on proposed revenue recognition standard (TNF 2012-462)
  • Defining Issues: SEC updates Q&As about JOBS Act (TNF 2012-469)
  • Defining Issues: FASB technical corrections, conforming amendments to “codification” (TNF 2012-470)
  • Defining Issues: FASB / IASB - Tentative decisions on contract manufacturing and modifications (revenue recognition) (TNF 2012-481)
  • Defining Issues: FASB to limit scope of new offsetting disclosures (TNF 2012-491)
• Treaty Update
  • Tax Treaty Update: Senate fails to act on treaty with Hungary, Protocols with Luxembourg and Switzerland (TNF 2012-11)
  • Tax treaty update: Income tax treaty with Chile (signed in 2010) sent to Senate; analysis of treaty’s provisions (TNF 2012-251)
  • Tax treaty update: New income tax agreement between United States and Spain is initialed (TNF 2012-275)
• Miscellaneous
  • KPMG analysis of the FATCA proposed regulations (TNF 2012-108)
  • KPMG analysis: Model I Intergovernmental Agreement released as alternative to FATCA regime (TNF 2012-360)
  • KPMG’s Inside Indirect Tax (April 2012) (TNF 2012-215)
  • KPMG’s Inside Indirect Tax (May 2012) (TNF 2012-258)
  • KPMG’s Quarterly Outlook: Review of accounting and financial developments (TNF 2012-158)
  • KPMG’s Quarterly Outlook: Review of accounting and financial developments (TNF 2012-308)
  • New medical device excise tax—Q&As (TNF 2012-20)
  • Tax guide for film and television industry (TNF 2012-170)
  • Obama administration’s corporate tax reform plan (TNF 2012-110)
  • Obama signs 2% payroll-tax cut legislation (TNF 2012-111)
  • Initial analysis of the Obama administration’s corporate tax reform plan (TNF 2012-112)
  • State tax guidance related to technology, cloud computing, and web-based business (TNF 2012-377)
  • Corporations that made accelerated credit election for 2008 and 2009 need to consider whether to continue that election in 2011 and 2012 (TNF 2012-400)
  • United States, Australia to consider intergovernmental agreement for FATCA implementation (TNF 2012-401)
  • OECD report on aggressive tax planning (TNF 2012-125)
  • OECD evaluates tax transparency in 11 countries (TNF 2012-182)
  • OECD model tax treaty to allow for information requests concerning groups of taxpayers (TNF 2012-342)
  • OECD requests for comments on proposals concerning definitions of beneficial owner, emissions trading, and permanent establishment (TNF 2012-478)
  • GAO report on the “tax gap” (TNF 2012-204)
  • GAO study on small employer health insurance tax credit (TNF 2012-256)
  • GAO report looks at appraisals for tax purposes (TNF 2012-328)