Internal Revenue Bulletin: 2008-19
May 12, 2008
Tax evasion; return-of-capital treatment. The Supreme Court holds that a distributee accused of criminal tax evasion may claim return-of-capital treatment without producing evidence that, when the distribution occurred, either he or the corporation intended a return of capital. Boulware v. United States.
Final regulations under section 6050L of the Code provide guidance for the filing of information returns by donees relating to qualified intellectual property contributions. These regulations reflect changes to the law enacted in 2004.
Proposed regulations under section 6323 of the Code relate to the validity and priority of the federal tax lien against certain persons. The regulations that implement section 6323 have not been amended for some time. The most significant of the proposed changes reflect that most liens filed by the IRS are now self-releasing, and reflect the authority of the IRS to file liens electronically without obtaining the permission of the locality. Other changes update the regulations by making various incidental changes to dates and other language contained therein.
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