The IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065) and a similar revised version of the 2022 S Corporation Instructions for Schedules K-2 and K-3 (Form 1120-S).

 

U.S. Federal Courts reached two important decisions on transfer pricing cases as 2022 came to a close.

 

In April of this year, the IRS released a memorandum announcing a change to IRS policy regarding the economic substance doctrine in audits.

 

Consolidated groups have the option to take the position that their aggregate 951(a)(1)(A) and 951A(a) inclusions are reduced by changing the ownership of stock of a CFC within the group. Specifically, taxpayers are taking the position that a group’s aggregate pro rata share of a lower-tier CFC’s subpart F income or tested income is reduced under section 951(a)(2)(B) by reason of both: 1.) a distribution made by the lower-tier CFC to a member, and 2.) a direct or indirect acquisition of stock of the lower-tier CFC by another member.

 

Jason Rauhe from our Global Business Services practice reflects on 2022.

On November 4, the Department of the Treasury and the Internal Revenue Service released the 2022-2023 Priority Guidance Plan. The Priority Guidance Plan is published to highlight what is most important for taxpayers and the tax administration.

The IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065) and a similar revised version of the 2022 S Corporation Instructions for Schedules K-2 and K-3 (Form 1120-S).

 

When helping clients get current with filing delinquent returns of prior years, we are always asked the question “How far back do we have to go?”

In this blog, Mark O’Dell, CPA, dives into how the IRS is enhancing its Transfer Pricing enforcement.

In a news release, the IRS reminded individuals and entities who missed the April 15 deadline for filing a Report of Foreign Bank and Financial Accounts (FBAR) to submit their annual report on or before October 17, 2022.

 

Jason Rauhe, CPA is a Principal in the firm’s Global Business Services practice and is responsible for assisting clients and adding depth in all areas of the firm’s international tax consulting services including transfer pricing, and the firm’s compliance expertise.

Rauhe previously served as Director of International Tax at a Top 100 CPA Firm, where he was responsible for the firm’s international tax division and major industry alliance networks.

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