United States: When Your Client Discovers It’s In A Tax Minefield, Consider A Voluntary Disclosure Agreement

Let’s assume that last week, your client wrapped-up a sales, use, rental and business license tax audit by a contract auditing firm that represents a number of cities and counties in the state. It turns out that your client has never filed a consumer’s use tax return. “Mercifully,” the examiner only went back six years, and not all the way back to the date your client first started doing business in the targeted localities. […]

By |October 18th, 2014|

United States: Missouri Administrative Hearing Commission Holds Group Filing

The Missouri Administrative Hearing Commission (AHC) has held that an affiliated group of corporations was not entitled to deduct, on its consolidated Missouri corporate income tax return, its members’ net operating losses (NOLs) reported on separate Missouri returns in prior years.1 A federal regulation expressly allows the separate company losses to be deducted on subsequent consolidated returns, but Missouri does not have a comparable statute or regulation.
Background
Prior to 2001, a taxpayer consisting of an […]

By |October 17th, 2014|

United States: IRS Will Not Impose The Simplified Production Method On Restaurants

In an IRS chief counsel advice memorandum released Sept. 26 (CCA 201439001), the IRS concluded that it generally would not support imposing the simplified production method on restaurants if the taxpayers are willing to develop and implement a reasonable facts-and-circumstances method instead. If those taxpayers use the simplified production method, the IRS also would support allowing them to treat direct production costs as Section 471 costs, rather than as additional Section 263A costs.

Restaurants generally […]

By |October 17th, 2014|