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Appeals Settlement Guidelines (ASG)

NOTE: Coordinators may have changed since settlement guidelines were published. Please refer to the Technical Guidance - International Index (PDF) for the latest coordinator contact information.

Abusive Tax Avoidance Transactions

Air Transportation

Cafeteria Plans

  • Heath Insurance Deductibility for Self-employed Individuals

COLI (Corporate Owned Life Insurance)

Commercial Banking

Construction/Real Estate

Employment Tax

  • Medical Resident FICA Refund Claims

Environmental

  • IRC 1341 Environmental Remediation Costs

Excise Tax

  • Virtual Private Networks

Food Industry

Forest Products

Fuel from a Nonconventional Source (FNS)

Gaming

I.R.C. § 118 SALT

  • State and Local Location Tax Incentives (I.R.C. § 118 SALT)
  • Exclusion of Income: Non-Corporate Entities and Contributions to Capital, I.R.C. § 118

Insurance – Life

Intangibles

Interest Computations

  • Net Rate Interest Netting - Requirement that Both Statutes be Open for Pre-98 Act Years
  • Overpaid Estimated Taxes

International

  • Foreign Sales Corporations (FSC) Advance Payment Transactions

Inventory

Leasing Promotions

Mare Leasing

Primary issue of whether expenses were incurred in carrying on a trade or business. Alternatively, whether individuals were materially participating and at risk; whether expenses were ordinary and necessary; and whether expenses should be capitalized or currently deducted.

Maquiladora

Media/Communications

  • Investment Tax Credit - Transition Property

Military

Mining

Motor Vehicle

Notional Principal Contracts

Partnerships

Petroleum

Pharmaceutical

  • Medicaid Rebates
  • Research and Experimentation Expenditures (Reg. 1.861-17(a)(4)

Research Credit

Retail

S Corporations

Savings and Loans

Securities & Financial Services

  • Transfer or Sale of Compensatory Options or Restricted Stock to Related Persons- Notice 2003-47

Shipping

Sports Franchises

State Refundable Credits

Telecommunications

Utilities

  • Investment Credit Transition Property
  • Membership Payments Made to Industry-created Research Organizations
Page Last Reviewed or Updated: 24-Nov-2014