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Tax Articles

IRS Transfer Pricing Compliance Programs Reorganization

The IRS Advance Pricing Agreement (APA) Program, concerned exclusively with reaching pre-filing agreements with taxpayers on transfer pricing, will shift from the office of IRS Chief Counsel to an office under the Transfer Pricing Director in the Large Business & International division’s international operation. In addition, the IRS Mutual Agreement Program (MAP), concerned primarily with…


IRS Restrictions on Contacting Taxpayers

The Treasury Inspector General for Tax Administration (TIGTA) recently issued Report Number: 2011-30-090. In this report it clearly states that Internal Revenue Service (IRS) employees are required to stop an interview if the taxpayer requests to consult with a representative and may not bypass a representative without supervisory approval. Evidently this is not happening as diligently…


IRS Treatment of Marijuana Dispensary Expenses

If you are in the business of dispensing marijuana according to the United States Office of Homeland Security you are selling an illegal drug not a medicine like many individual states believe. Nevertheless Internal Revenue Code IRC 280(E) states that the expenses associated with selling illegal drugs are not deductible from revenue when calculating federal income for…