IRS UPDATES AMPLE DISCLOSURE RULES FOR TAX POSITIONS

Washington, D.C. -- The IRS released its annual update identifying the circumstances under which the disclosure on a taxpayer's income tax return with respect to an item or a position is adequate for the purposes of reducing the understatement of income tax and avoiding the tax return preparer penalty.

The IRS noted that Revenue Procedure 2012-51 does not apply with respect to any other penalty provisions.

It also noted that if the revenue procedure does not include an item, disclosure is adequate with respect to that item only if made on a properly completed Form 8275 or 8275-R, as appropriate, attached to the return for the year or to a qualified amended return.

The new revenue procedure applies to any income tax return filed on 2012 tax forms for a taxable year beginning in 2012, and to any income tax return filed on 2012 tax forms in 2013 for short taxable years starting in 2013.

The IRS noted that editorial changes have been made throughout the revenue procedure, but no substantive changes have been made.

 

IRS, TREASURY SET PRIORITIES FOR TAX GUIDANCE

Washington, D.C. -- The IRS and the Treasury Department released the 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.

Topics in the plan include transfer pricing, outbound transactions, consolidated returns, employee benefits, excise taxes and tax-exempt organizations.

The IRS and the Treasury Department plan to provide regulations for corporations and shareholders regarding the recovery and allocation of basis in redemptions, organizations and re-organizations.

For 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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