This letter to the Treasury and the IRS is in response to Notice 2-43's request for recommendations for the 2-2 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. Many of...

This letter to the Treasury and the IRS is in response to Notice 2019-30's request for recommendations for the 2019-2020 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance....

This is a letter to the editor of Tax Notes Federal that highlights some changes to subsections (d) and (e) of section 954. These are the definitional rules for what is foreign base company sales income and foreign base company services income.I see this as something that was likely drafted by a...