TCJA Section 13521 reverses the effects of IRS Revenue Ruling
2009-13 for life settlement transactions entered into after Aug.
In Revenue Ruling
77-17, the IRS addressed the treatment of losses that result from fraudulent activities.
2010-5 allows disclosure of taxpayer names and type of services provided by a preparer to the extent necessary to obtain professional liability insurance coverage, including obtaining price quotes for coverage.
2009-13 indicates that cost of insurance must be subtracted from the total premiums paid to determine basis.
Section 401(a) of the Internal Revenue Code requires that, to qualify for pension plan tax breaks, an employer-sponsored plan "must be for the exclusive benefit of its employees or their beneficiaries," IRS officials write in the revenue ruling
In its revenue ruling
issued on February 21, 2008, the IRS explained that an employee could leave for "good reason" or be terminated without "cause" simply because that employee missed interim performance targets.
The court looked favorably on the IRS's citation of Revenue Ruling
75-44 and took an expansive view of wages.
Two states--California and Florida--reviewed the Revenue Ruling
in draft form and agreed with it, noting that their members had raised concerns similar to those the AICPA expressed.
South Carolina: Delivery of TPP in company-owned delivery trucks is a protected activity; see SC Revenue Ruling
(38) The regulations implement this resolve by essentially removing all discretion from everyone within the IRS and Treasury other than the senior-most leadership (those that have final approval of all regulations and revenue rulings
) in identifying "significant future benefits" requiring capitalization.
Along with the revenue procedure, the IRS issued Revenue Ruling
2002-35, which clarifies that payments to employees for equipment they are required to provide as a condition of employment are wages for federal employment tax purposes, unless such payments are paid under an accountable plan.
15, the IRS issued a revenue ruling
agreeing that impact fees paid by developers are part of the cost of doing business and can be used in calculating the Low Income Housing Tax Credit.