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IRS Insights - May 2014


Deloitte ImageWelcome to the bimonthly publication, IRS Insights, produced by the Deloitte Tax Controversy Services group to keep our clients abreast of current issues related to the Internal Revenue Service.

In this month's issue:

  • IRS Provides for Automatic Determination Under Treas. Reg. § 1.1502-75(b) to Treat a Subsidiary that Failed to File a Form 1122 as Joining in the Making of a Consolidated Return by the Affiliated Group
  • Office of Chief Counsel Releases GLAM Discussing the Tax Consequences of an Invalid Section 953(d) Election
  • Large Business & International Division Revises Information Documentation Request Policies
  • IRS Publishes Guidance on How Tax Principles Apply to Transactions Using Convertible Virtual Currency: IRS Will Treat Virtual Currency as Property for U.S. Federal Tax Purposes
  • Tax Court Discusses Attorney-Client Privilege and Waiver in Tax Shelter Penalty Case

See attached file for details.

Visit the IRS Insights archive for issues from the past year.

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