TEI inquired when the IRS might issue regulations in respect of the treatment of costs related to tangible assets or repairs.
The project is intended to bring the regulations up to date, especially in respect of the changes in transfers of technology.
Sweetnam said that he has been meeting with the IRS LMSB Division in respect of the employment tax deposit issue.
* TEI has long supported the establishment of an effective disclosure regime in respect of taxpayers, promoters, and advisers who may be involved in the development and marketing of potentially abusive tax shelters.
* Exceptions in respect of confidentiality for (i) M&A agreements (including letters of intent) and (ii) communications with the taxpayer's counsel.
In addition, does Treasury contemplate issuing rules in respect of nonqualified deferred compensation plans similar to the May 2002 regulations issued under section 457, which would liberalize the rules relating to monthly deferral elections, redeferral elections, and distribution/method of payment elections?
In some cases, the use of costs (e.g., in respect of research and development) may be an appropriate way of applying a profit-split method.(4) Of course, taxpayers using a profit-split approach should provide reasonable financial documentation to the tax administration in support of that methodology.
approach to penalties (especially in respect of documentation and post-year end compensating adjustments) and that of other OECD members.