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IRS and Treasury Set Priorities for Tax Guidance

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Washington, D.C. (November 30, 2012)

By Michael Cohn

The Internal Revenue Service and the Treasury Department have released their 2012-2013 priority guidance plan outlining 317 projects that they plan to prioritize from July 2012 to June 2013 in providing guidance and regulations to tax practitioners.

Among the topics described in the plan they released last week are transfer pricing, outbound transactions, consolidated returns, employee benefits, excise taxes and tax-exempt organizations.

In the area of corporations and shareholders, for example, they plan to provide regulations regarding the recovery and allocation of basis in redemptions, organizations, and reorganizations; final regulations regarding the allocation of earnings and profits between a transferor and a transferee corporation when assets are transferred in connection with a reorganization, and guidance regarding transactions involving the transfer of or receipt of no net equity value.

On the topic of retirement benefits, the IRS and the Treasury Department plan to provide guidance on exceptions to additional taxes on early distributions from retirement plans and IRAs, as well as regulations on the application of the normal retirement age regulations to governmental plans.

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