Tax Dispute Resolution Quarterly

IRS practice & procedure
FBAR reporting: Changes are in the wind
Given the global trend in tax transparency and the U.S. government’s heightened
enforcement thrusts against unreported foreign earnings, the requirement to annually
report foreign financial accounts on FinCEN Form 114, Report of Foreign Bank and
Financial Accounts (FBAR), has become an area of increased focus. (Read more...)
JCT ‘Bluebook’ description of partnership audit reforms
In mid-March, the staff of the Joint Committee on Taxation (JCT) released its General
Explanation of Tax Legislation Enacted in 2015 (JCS-1-16)—known as the “Bluebook,”
which contains considerable additional information about the partnership audit reform
law and clarifies some issues about which questions have been raised (as well as other
provisions enacted last year) (Read more...)
LB&I updates Publication 5125 and Internal Revenue Manual
The IRS recently revised Publication 5125 to provide guidance on changes to the
Large Business and International (LB&I) examination process resulting from the recent
restructuring of LB&I (Read more...)
Applying sec.1032 to share-based awards for international employees.
Multinational employers often grant employees of foreign subsidiaries share-based
awards—stock options, restricted stock, and other equity-type awards—that are
satisfied with stock of the U.S. parent corporation (Read more...)
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