It has been argued that the private ruling
system developed into a body of law known only to a few members of the tax profession.
Internal Revenue Service where he was responsible for issuing and reviewing private ruling
letters and revenue rulings.
In a private ruling
that will affect CPAs in public practice as well as their clients, the IRS acknowledged a partner in a professional firm could deduct auto, travel and meal expenses on form 1040 if the partnership policy requires the expenses to be incurred personally without reimbursement (technical advice memorandum 9316003).
355/D reorganization transaction based on the relative FMVs of the distributing and controlled corporations is a standard representation that the Service requires in private ruling
The approvals follow upon an understanding between Alcoa and the Federal Anti-Monopoly Service (FAS) resulting in an FAS private ruling
on behavioral conditions to ensure that Alcoa complies with various legal requirements and notification obligations.
An effective date for the conversion and split will be announced upon receipt of a private ruling
from the IRS, which is pending.
The consummation of the transactions described above is contingent upon a number of matters including, without limitation, the receipt of a report from the special committee recommending approval by Atek's board, the receipt of an opinion from an investment banker to the effect that the proposals from a financial point of view are fair to the public shareholders, approval of the transactions by Atek's board of directors, approval of the proposed merger by Atek's shareholders and the receipt of a private ruling
letter from the Internal Revenue Service to the effect that the transactions will be tax-free to Atek and to these executive officers and members of their families.
The private ruling
is significant because it formally states the IRS's position on the taxability of frequent-flier miles.
As a hybrid of the wholly prospective transaction-based private ruling
approach of Rev.
The corporation sought a private ruling
that it would not be subject to the New York corporation franchise tax if (1) it employed independent brokers to trade in commodity futures contracts in precious metals on a New York exchange, and (2) in certain situations, it took title to the metals for short periods of time (the metals would be located in warehouses or vaults in New York).
Where the private ruling
process is used, however, the facts may be obscured, the legal analysis shielded from scrutiny, and taxpayers as a whole disadvantaged.
Where the private ruling
process is used, however, the facts are obscured, the legal analysis is shielded from scrutiny, and taxpayers as a whole are disadvantaged.