We also recommend that if claims are made about products or services, that clients keep all substantiating
materials in a readily accessible location so that substantiation notices are easily responded to, in light of the 21 day time period.
Under current law, taxpayers must document their contributions (and other deductions) because they shoulder the burden of proof (and have access to the records -- if any -- substantiating
CPAs should be prepared to defend them as reasonable with some form of substantiating
evidence, and to have available documentation for significant expenses incurred since the disaster.
Thus, the existing technical documentation should be the starting point for substantiating
the standards of the new final regulations; any gaps can be filled in or clarifications provided by credit-specific documentation.
the allocation of damages can dramatically improve an investor's subsequent tax treatment; this requires investors to consider the tax consequences of the damage payments froth the start of the dispute.
private offerings by reviewing, structuring, and substantiating
Taxpayers are required to maintain books and records in accordance with the prescribed rules and regulations and to bear the burden of proving and substantiating
In particular, INTEGRAL demanded that IAS produce evidence substantiating
the allegations it made against INTEGRAL and its subsidiaries.
274-5T(c)(2)(iii) requires substantiating
documentary evidence for any expenditure for lodging and any expenditure of $75 or greater.
Research Report Substantiating
'Buy' Recommendation Available
Although no specific rules were ever issued by the Service, employers universally treated the 20 % as nondeductible at the employer level, and no amount was included in the employee's income, as long as the employee met the rules for substantiating
the expenses under a reimbursement arrangement; see Sec.
The IRS has issued a proposed revenue procedure that would allow employers to use alternative methods for substantiating
compliance with the pension plan nondiscrimination requirements.