The IRS recently issued Revenue Procedure 2014-12, providing a safe harbor under which the IRS will not challenge partnership allocations of “section 47” federal rehabilitation tax credits.
Otto von Bismarck is credited with the saying, “Law and sausage are two things you do not want to see being made.” This might be unfair to current artisanal dry-cured meat producers, but it is still quite the case with Congress.
Over the last decade, there have been numerous class actions regarding telecommunication companies’ use of railroad easements.
In Section 9.03(3) of the new Revenue Procedure 2014-4, the IRS has clarified that the option to request expedited handling is no longer available for determination letters.
Effective January 1, 2014, the IRS is using a new form – Form 8822-B – for organizations to report changes to their “responsible party.” Form 8822-B applies to all entities with a federal employer identification number (EIN), and includes a box to check if the organization is tax-exempt.