Internal Revenue Bulletin: 2008-15
April 14, 2008
This notice provides interim rules for contingent fees under section 10.27(b)(2) of Circular 230. Specifically, this notice provides (1) A clarification that the “within 120 days of the taxpayer receiving a written notice of the examination of, or a written challenge to the original tax return” language in section 10.27(b)(2)(ii) does not require the IRS to furnish the written notice of examination to a taxpayer as a prerequisite to a practitioner charging a contingent fee and (2) A new exception under section 10.27 that allows practitioners to charge a contingent fee with respect to whistleblower claims under section 7623(b) of the Code. The IRS will apply the interim rules under section 10.27(b)(2) in the notice until the Treasury Department and the IRS amend the regulations.
This document contains corrections to final and temporary regulations (T.D. 9368, 2008-6 I.R.B. 382) regarding the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Code. The regulations affect taxpayers claiming foreign tax credits and provide guidance needed to comply with the statutory changes made by the American Jobs Creation Act of 2004 (AJCA).
This document cancels a public hearing on proposed regulations (REG-141399-07, 2008-8 I.R.B. 470) providing guidance relating to the recapture of overall foreign and domestic losses.
|More Internal Revenue Bulletins|