Post by Sapphire Capital on Aug 13, 2008 0:56:10 GMT 4
US authorities look for suggestions for new guidance
International Tax Review
The Internal Revenue Service in the US wants industry associations and taxpayers to make proposals for the upcoming review in the Industry Issue Resolution (IIR) Programme.
The initiative seeks to produce guidance that solves business tax issues for a large number of taxpayers.
An IIR team from the IRS and Treasury researches each proposal selected by speaking to taxpayers and others. The guidance to resolve the issue is aimed at cutting out the time and money that taxpayers and the tax authorities spend going through an examination process.
The IRS explains that suitable issues for the IIR programme cover where
• the proper tax treatment of a common factual situation is uncertain;
• the uncertainty results in frequent, and often repetitive, examinations of the same issue;
• the uncertainty results in taxpayer burden;
• the issue is significant and impacts a large number of taxpayers, either within an industry or across industry lines; and
• the issue requires extensive factual development, and an understanding of industry practices and views concerning the issue would assist the Service in determining the proper tax treatment.
The IIR programme would not cover issues that:
• are unique to one or a small number of taxpayers.
• are primarily under the jurisdiction of operating divisions of the Service other than the LMSB [Large and Mid-Sized Business Division] and SB/SE [small business/self-employed] divisions.
• involve transactions that lack a bona fide business purpose, or transactions with a significant purpose of improperly reducing or avoiding federal taxes.
• involve transfer pricing or international tax treaties.
The IRS reviews proposals for the IIR programme twice a year.
International Tax Review
The Internal Revenue Service in the US wants industry associations and taxpayers to make proposals for the upcoming review in the Industry Issue Resolution (IIR) Programme.
The initiative seeks to produce guidance that solves business tax issues for a large number of taxpayers.
An IIR team from the IRS and Treasury researches each proposal selected by speaking to taxpayers and others. The guidance to resolve the issue is aimed at cutting out the time and money that taxpayers and the tax authorities spend going through an examination process.
The IRS explains that suitable issues for the IIR programme cover where
• the proper tax treatment of a common factual situation is uncertain;
• the uncertainty results in frequent, and often repetitive, examinations of the same issue;
• the uncertainty results in taxpayer burden;
• the issue is significant and impacts a large number of taxpayers, either within an industry or across industry lines; and
• the issue requires extensive factual development, and an understanding of industry practices and views concerning the issue would assist the Service in determining the proper tax treatment.
The IIR programme would not cover issues that:
• are unique to one or a small number of taxpayers.
• are primarily under the jurisdiction of operating divisions of the Service other than the LMSB [Large and Mid-Sized Business Division] and SB/SE [small business/self-employed] divisions.
• involve transactions that lack a bona fide business purpose, or transactions with a significant purpose of improperly reducing or avoiding federal taxes.
• involve transfer pricing or international tax treaties.
The IRS reviews proposals for the IIR programme twice a year.