IRS procedures for offers-in-compromise under section 7122

Article Abstract:

Changes in IRS procedure and statutory revisions have modified the offer-in-compromise program. Under IRC section 7122, the IRS delegates some authority to enter into compromises with taxpayers to specific personnel. Offers-in-compromise no longer require the approval of the IRS Chief Counsel if the amount involved is less than $50,000. The IRS has developed a new form, Form 656, and information booklet for submitting an offer. The IRS has established national and local living expense standards that are the maximum that taxpayers may claim on Form 433-A.

Tax Administration, Management, United States. Internal Revenue Service, Tax compromises

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Mergers & acquisitions: tax strategies

Article Abstract:

Special tax accounting rules applicable to tax-free mergers and acquisitions should be understood to assure receipt of the available tax benefits. Accounting and taxation areas at issue include purchase accounting, interest pooling, business purpose, step-transaction doctrine, continuity of stockholder interest, continuity of business, and boot. Different approaches apply to type A, B, and C reorganizations.

Mergers & Acquisitions, Corporate Tax Administration, Taxation, Acquisitions and mergers, Tax accounting, Corporate taxes, Tax planning

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