The IRS on Aug. 24 updated the Internal Revenue Manual (IRM) to
reflect changes to the way the Appeals Division functions, In
Notice 2016-59, the IRS provided changes to Rev. Proc. 2016-1,
which governs the procedures and cost for obtaining a private
letter ruling (PLR) from the IRS Office of Chief Counsel.
Under Rev. Proc. 2016-1, the current user fee for a PLR is
$28,300. Taxpayers requesting a PLR may qualify for a reduced user
fee for a substantially identical PLR if the subsequent PLR is
requested for multiple entities with a common member or sponsor, or
multiple members of a common entity. The reduced user fee for each
substantially identical PLR is $2,700.
The notice expands the availability of the reduced user fee to
include substantially identical PLRs requested by parties that are
engaged together in the same transaction affecting all requesting
taxpayers. The change is effective immediately and will be
reflected in Rev. Proc. 2017-1, which is typically published in
early January of each year. Finally, the notice also
decreases the user fee for a request for a Foreign Insurance Excise
Tax Waiver Agreement from $8,000 to $7,200, for requests received
after Feb. 4, 2016. The IRS said the reduced fee was omitted
inadvertently from Rev. Proc. 2016-1.
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The Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
One of the most publicized and long-awaited business provisions contained in the Omnibus Budget Reconciliation Act of 1993, P.L. 103-66, 107 Stat. 312 (1993) (the "1993 Act") was section 197 of the Internal Revenue Code of 1986 (the "Code"), which governs the tax treatment of acquired intangible assets. However, section 197 cannot be analyzed in isolation. Since it comes into play whenever there is an allocation of consideration to an amortizable section 197 intangible, a basic understanding of
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