To further confuse matters, some of the timing provisions explicitly delay withholding and information reporting (see Treas.
The contributions must be substantiated following the guidelines of Treas.
If an outstanding debt instrument is modified, or is exchanged for a new debt obligation of the issuer, a taxable exchange will occur if the terms of the outstanding instrument (hereinafter, the "old debt") are significantly modified within the meaning of Treas.
Each of the taxpayer's real estate interests is treated as a separate activity for these tests; however, Treas.
85) The request must contain the appropriate information and statements outlined in Treas.
IRC [section] 7216 provides a criminal penalty (along with the civil penalty of section 6713) for any tax return preparer who "knowingly or recklessly" discloses or uses tax return information, with those terms and others defined by the 2008 final regulations (TD 9375, amending Treas.
2000-42, which provides guidance on executing closing agreements pursuant to Treas.
In a recent chief counsel advice, the IRS held that certain allowances resellers receive from vendors for defective merchandise should be treated as reducing the cost of inventory under Treas.
605) inviting public comment on the treatment of transaction costs that are required to be capitalized under section 263(a) of the Internal Revenue Code and Treas.
12) This rule also applies to determine the person who is considered to have legal liability for, and thus, to have paid a tax in lieu of an income tax (within the meaning of Treas.
If there is not time to wait for Form 8855 to become available, Treas.
Court of Appeals for the Ninth Circuit held that employee stock option (ESO) costs incurred by one company participating with related companies in a cost-sharing agreement (CSA) in the late 1990s must be allocated among the research and development (R&D) costs of all the participants under former Treas.