Interest Paid by Foreign Disregarded Entity Was U.S. Source Income

The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign

Read more

TIGTA Finds Fault with Existing IRS Safeguards for Taxpayer Information Released to Health Care Exchanges

In an audit report released on October 23, 2014, the Treasury Inspector General for Tax Administration (TIGTA) has found that the IRS should revise its procedures to better ensure protection of federal tax information scheduled to be released to the health care exchanges under the Patient Protection

Read more

IRS Will Work with Taxpayers Liable for Individual Shared Responsibility Payment

Individuals liable for the Code Sec. 5000A shared responsibility payment will make their payments when they file their 2014 returns, William Smits, senior manager, IRS Wage & Investment Division, National ACA Outreach Coordinator for Individual Tax Provisions, reminded practitioners during a webcast sponsored by the American Institute

Read more

IRS Provides IRA Owners with Fresh Start for Rollovers in 2015

The IRS has provided transition relief for its change in the one-per-year limit imposed on tax-free rollovers between Individual Retirement Account (IRA) announced in March 2014. and scheduled to go into effect January 1, 2015. Under the change, the one-per-year rule applies to each individual rather than

Read more