2016 Foreign Housing Limitation Adjustments

The Internal Revenue Service (IRS) recently issued Notice 2016-21, setting the country-by-country limitation on housing expenses deductible under section 911 of the Internal Revenue Code for 2016. The housing expenses deduction enables a qualifying taxpayer to include...

Taxpayer Advocate’s Review – 2015 filing season

The Taxpayer Advocate’s review of the 2015 filing season commented that the IRS faced extraordinary challenges during the filing season. ‘The IRS continues to view itself, first and foremost, as an enforcement agency, and it thus develops its policies...

IRS Notice 2015-79 Inversions & Related Transactions

The IRS has announced it will tighten its anti-inversion rules in Notice 2015-79, issued last week, through regulations which will address tax avoidance transactions at the time of, and post-inversion. Internal Revenue Code section 7874 (Rules Relating To Expatriated...

Tax Extenders Bill Countdown

“We are the only nation in the world that lets a huge chunk of its tax code expire, often for a year, and then retroactively puts it back in place.” “That whole process is really unacceptable to me, and it puts us out of place with the rest of the...

IRSAC 2015 Annual Report released

The 2015 annual report was presented to the IRS Commissioner yesterday. The report consists of four sections: 1. General report, addressing the following: Issue one: The IRS needs sufficient funding to operate efficiently and effectively, provide timely and useful...