The Treasury Department and the IRS released their 2017-2018 Priority Guidance Plan, which prioritizes various tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. The new plan takes into account various Executive Orders issued this year directed at administrative regulations.

Executive Orders

Since taking office, the

The IRS is putting an increased emphasis on identity theft protections for business returns as a result of an increase in fraudulent business tax returns in recent years. The IRS will be asking tax professionals to gather more information on their business clients to assist the IRS in authenticating that the tax return being submitted

Statutory Background

When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered into bilateral tax treaties with numerous countries. The bilateral tax treaty between the U.S. and Switzerland entitles Swiss-resident entities to a reduction in

The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident alien individuals for interest paid on or after January 1, 2017. Back in December, we discussed the previous additions to the list of participates

On November 1, 2016, the IRS issued Notice 2016-66 imposing new reporting requirements on micro-captives and their material advisors (see prior post describing the Notice). On March 27, 2017, CIC Services, LLC and Ryan, LLC filed a complaint against the IRS seeking a preliminary injunction prohibiting the IRS from enforcing the disclosure requirements in

On January 20, 2017, the White House issued a Memorandum freezing all new regulations (former President Obama issued a similar freeze at the start of his administration).  In addition, on January 30, 2017, the President issued an Executive Order requiring federal agencies to eliminate two prior regulations for every new regulation issued.  The regulatory freeze

Previously, we discussed Congress’s enactment of the FAST Act requiring the IRS to use private debt collection agencies to recover inactive tax receivables. In September, the IRS announced that it had contracted with four collection agencies to begin private collection, and last week, the IRS posted to its website a sample of the letter it