Pre-Filing Agreement Program Issues Successfully Completed



This is a list of all the issues accepted into the Pre-Filing Agreement Program and completed with a closing agreement as of 12/31/13.

Amount of Qualified Research and Experimental Credit

Treatment of License Fee Income

Deductibility of Fees to Purchase Tax Exempt Securities and Stock

Gain/ Loss on Sale/Exchange/Transfer of Stock /Property

Worthless Securities and Bad Debts 

Fuel Credit

Writedown of Inventory

Deductibility of Fines/ Penalties/Settlement Fees & Defense Costs

Basis/FMV of Stock Acquired

IRC 199, Domestic Production

Disposition of Subsidiary

Deductibility of Merger/Acquisition Costs

Abandonment Loss

Like-Kind Exchange

Effectively Connected Income

Deductibility of Termination Fee

Interest Deduction

Withholding & Reporting FICA, Interest, Dividends, & Income

Apportionment of General and Admin Expenses

Repatriation of Earnings

Debt Issues

Valuation of Property for Rehab Credit

Loss on Seized Assets

Permanent Establishment

Earnings and Profits

Deductibility of Parachute Payments

Discharge of Indebtedness

Character of Loss

Depreciation Issues – cost segregation study, amortization vs. capitalization, recovery periods, placed in service date

Built in Gain from Acquisition/Sale

Substantiation Required for Tax Deduction

Correction of Overaccrued Tax Liability

Deduction for Collectively Bargained Welfare Benefits

Deductibility of Payments to Retire Debt

Valuation of Assets

Method of Accounting

Stock Basis Computation

Investigatory Costs 

FMV of Assets Exchanged for Stock in a Tax-Free Exchange Pursuant to a Reorganization Plan   

Deductibility of Fees Incurred in a Reorganization 

Bad Debt Deduction for Intercompany Advances 

Amount/Utilization of Net Operating Loss  

Start-up costs and Operating Expenses 

Fair Market Value of Stock Contributed to Pension Plan 

Deductibility of Interest

Determination of Whether Taxpayer is a US real Property Holding Company

Amortization of Intangibles

Deductibility of Indemnification Payments

Creditability of Gaming Tax

Eligibility to make a Deemed Sale Election

Involuntary Conversion

Determination of Whether Taxpayer is a Domestic Corporation
Medical Device Excise Tax