The Internal Revenue Service issued its 27th annual report on the Advance Pricing and Mutual Agreement (APMA) Program, providing critical insights into transfer pricing enforcement trends for 2025. Announcement 2026-8, released in Bulletin No.
The Tax Court’s April 8 ruling in Varian Med. , Inc. & Subs. v. 3 million foreign tax credit disallowance—highlighting the high-stakes transition from the old worldwide tax system to the TCJA’s territorial regime.
S. Tax Court. Pratt’s $10,000 dispute wasn’t just about the money; it was a jurisdictional showdown testing whether the Tax Court could assert authority over the IRS when no administrative or judicial action had been taken against the target taxpayer. C. Circuit’s recent decision in Kennedy v.
The IRS Bulletin No. 2026-15 arrives amid a period of heightened regulatory flux, where long-standing provisions intersect with evolving legislative priorities and emerging economic realities.
48-4 election for qualified rehabilitation expenditures (QREs). The taxpayer’s accounting firm inadvertently failed to file the election with the original tax return, prompting the request for relief.
9100-3 to a partnership that missed a timely § 754 election after a partner’s death, ruling the failure was inadvertent and not prejudicial to the government.
A taxpayer’s $A in deferred capital gains hung in the balance when an overlooked regulatory deadline threatened to disqualify their Qualified Opportunity Fund (QOF) election. 9100-3, which allows extensions for regulatory elections when taxpayers act reasonably and in good faith.
The IRS granted an LLC’s request for both an extension to file a late S corporation election and entity classification relief after the company inadvertently failed to submit Form 2553 on time.
The IRS granted a taxpayer’s request for an extension to make a late § 168(h)(6)(F)(ii) election, allowing the taxpayer to avoid tax-exempt entity status for depreciation purposes.
The IRS granted a taxpayer’s request for regulatory relief after a tax advisor’s oversight led to a missed deadline for electing Qualified Opportunity Fund (QOF) status, saving the taxpayer from a potential $A loss.
The IRS granted a 120-day extension under Treas. Reg. 9100-3 to X, a state LLC taxed as a partnership, to file a late § 754 election for its taxable year ended Date 1.
The IRS granted a 120-day extension to a partnership that missed its § 754 election deadline, ruling the taxpayer acted reasonably and in good faith.
9100-3 for a taxpayer and transferee to make a late §362(e)(2)(C) election after failing to comply with regulatory deadlines.
The IRS granted a 75-day extension to a taxpayer and transferee for entering into a binding agreement and filing an election statement under Section 362(e)(2)(C), which governs basis adjustments in tax-free corporate formations.
The IRS has granted a 75-day extension to a taxpayer seeking to file a late closing-of-the-books election under Section 382, allowing the corporation to offset post-change taxable income with pre-change losses.
1502-75(a)(1) of the Income Tax Regulations, permitting the affiliated group to designate the parent corporation as the common parent for the taxable year ending Date 1. 9100-3 of the Procedure and Administration Regulations.
Taxpayers recently secured a 120-day extension under Section 2642(g) of the Internal Revenue Code to retroactively elect out of the automatic allocation of their Generation-Skipping Transfer (GST) exemption under Section 2632(c)(5).
The IRS granted relief to a state limited liability company (LLC) that inadvertently missed deadlines for both an entity classification election and an S corporation election.
In a rare and narrowly tailored decision, the IRS granted a private letter ruling (PLR-114045-25) allowing a taxpayer to retroactively elect under §336(e) to treat a stock sale as an asset sale, despite missing the regulatory deadline.
A domestic limited liability company (LLC) narrowly avoided default classification as a disregarded entity after the IRS granted a 120-day extension to file Form 8832, Entity Classification Election. 7701-3 but missed the filing deadline, risking retroactive tax liabilities and compliance penalties.
S. domestic corporations for federal tax purposes—and the agency granted consent, effective January 1, 2025. S. taxation under the election.
An estate recently secured a 120-day extension to make a QTIP election under § 2056(b)(7) after an accounting firm’s error nearly cost it a critical marital deduction. 9100-3, which allows extensions for regulatory elections when taxpayers act reasonably and in good faith.
The IRS granted a 120-day extension under Treas. Reg. 9100-3 for a taxpayer’s late Qualified Subchapter S Subsidiary (QSub) election under § 1361(b)(3), after determining the failure resulted from an inadvertent error with no tax avoidance motive.
9100-3 to a foreign entity seeking to file Form 8832 to elect corporate classification, resolving a late classification election request. 9100-3, which permits extensions when reasonable cause is demonstrated.
The IRS granted relief to a taxpayer seeking to file a late S corporation election under Section 1362(b)(5) of the Internal Revenue Code, allowing the election to be treated as timely if the taxpayer submits a completed Form 2553 within 120 days of this letter and includes a...
The IRS granted a 120-day extension to an LLC that missed the deadline to file Form 8832, the Entity Classification Election, after revoking its S corporation status.
The IRS granted a 120-day extension to a taxpayer who failed to elect out of the automatic Generation-Skipping Transfer (GST) exemption allocation for transfers totaling millions of dollars to three irrevocable trusts.
The IRS has ruled that a charitable lead annuity trust (CLAT) may accelerate all remaining annuity payments to a donor-advised fund (DAF) and terminate early without triggering penalties under Section 4941 (self-dealing), Section 4945 (taxable expenditures), or Section 507 (termination taxes).
The IRS granted relief under Section 1362(f) to an S corporation whose status terminated after a trust failed to file a required Qualified Subchapter S Trust (QSST) election on time, potentially exposing the company to millions in double taxation.
The IRS ruled that rental income received by an S corporation was not passive investment income under § 1362(d)(3)(C)(i), concluding that the corporation’s active involvement in managing and operating its rental properties disqualified the income from passive classification.