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Tax Articles

Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola’s SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC 482 – Allocation of Income and Expenses Among Taxpayers because of…


Procedures for Requesting Competent Authority Assistance under US Tax Treaties

U.S. competent authority assistance is not necessarily contingent upon whether you sign an agreement with the IRS Examination function contrary to the assertions of some IRS Revenue Agents. Turns out this is important information for some US Taxpayers of international origin in battle with the IRS. Yes there are good and bad people EVERYWHERE, including some…


General ITIN References & Contact Information Including IRS Pub 1915 & IRS Rev Proc 2006-10

Aside from this tax blog the following are the most useful resources for researching Individual Taxpayer Identification Number (ITIN) application processing. IRS Publication 1915 General ITIN Information page Update to the Instructions for Form W-7 and ITIN Processing Time IRS Rev Proc 2006-10 IRS Form W-7 IRS Form W-7 Instructions If you need assistance in…


Brian Dooley’s Tax Research Tool

I was reminded late last night while knee deep in yet another complex file that one of my many blessings has been the opportunity to connect on several distinct levels with many different people all over this great planet. From introspective artists in San Francisco to international bankers in Moscow, coffee plantation owners in El…


IRS Proposes Elimination of Automatic Filing Extensions for W-2 Forms

I tend to harbor deep resentment whenever the IRS proposes more restrictions on job creating taxpayers. After all WE are the backbone of the US economy and our government agencies absolutely must focus on mitigating obstacles for hard working entrepreneurs in their daily struggle to create new jobs. However as a person who prepares, signs and files…


Foreign Investment in Real Property Tax Act and Your TIN – IRC 897, 1445; TD 9082; IRS Form 8882, W-7

As part of an IRS Examination under the Foreign Investment in Real Property Tax Act (FIRPTA) you absolutely must have a Taxpayer Identification Number (TIN) to mitigate 26 U.S. Code § 1445 – Withholding of tax on dispositions of United States real property interests If you do not qualify for a Social Security Number (SSN) you may…


Exceptions to the requirement that a U.S. Federal Income Tax Return Accompany an ITIN Application – IRS Form W-7

You can indeed claim an exception to the requirement to submit an original U.S. Federal income tax return with IRS Form W-7 – ITIN Application, all you need is substantiated proof of your claim. So what are the exceptions allowing for the ITIN application without a tax return and how do you substantiate your claim? Exception 1.…