Tax practice

Ford Motor Co. is suing the Internal Revenue Service, claiming the agency owes the automaker $445.3 million in interest on tax overpayments.

The Internal Revenue Service has begun issuing summonses as it investigates Colorado's program for conservation easement tax credits.

Federal Reserve Chairman Ben Bernanke and Treasury Secretary Henry Paulson expressed their support for the convergence of International Financial Reporting Standards with U.S. generally accepted accounting principles.

Sen. Chuck Grassley, R-Iowa, ranking member of the Senate Finance Committee, provided an update this week on his correspondence with several media-based ministries about issues related to their tax-exempt status, indicating that some ministries have not been answering his questions.

The U.S. Court of Appeals for the Sixth Circuit issued an opinion in a tax dispute that found the U.S. Tax Court is not a court as defined by law.

A jury returned guilty verdicts against Joseph H. Smith, the former treasurer, CFO and legal secretary of the Catholic Diocese of Cleveland, on charges of conspiracy and filing false tax returns.

CCH began offering Global Daily Tax News on its CCH Tax Research Network, providing country-specific national and local tax and business news coverage to help users remain in compliance and support their tax planning.

The Senate Foreign Relations Committee held hearings on proposed tax treaties and protocols with Canada, Iceland and Bulgaria.

National Taxpayer Advocate Nina Olson has released a report outlining her office’s priorities over the coming fiscal year, including improving Internal Revenue Service procedures to protect victims of tax-related identity theft and helping people who have lost their homes to foreclosure.

The Internal Revenue Service has issued a new revenue procedure that aims to clear up some of the murkiness surrounding subprime loans and the tax treatment of securitized versions of those loans, though the murkiness is likely to remain for the majority of those loans anyway.

2009 HSA LIMITS RELEASEDWashington, D.C. — The Internal Revenue Service has published the 2009 inflation-adjusted deduction limits for health savings accounts.

So far, 2008 has not been a year for major tax legislation.Nor, being an election year, are the remaining six months likely to offer major legislation. Two bills that did make it through Congress prior to Memorial Day included tax provisions focused on farmers and alternative energy and on military personnel and veterans. The farm legislation required the override of a presidential veto and included a procedural snafu where one of the non-tax titles of the legislation was not forwarded to President Bush along with the rest of the legislation. Barring any litigation over that issue, the enactment date of the legislation is May 22, 2008.

The state of e-services today can be compared to where e-filing was about five years ago.“If you look back five years, what we were saying about e-filing would sound a lot like what we’re saying about e-services today,” said Roger Harris, president of Padgett Business Services and former chair of the Internal Revenue Service Advisory Council. “As practitioners and the IRS worked together, a lot of problems were solved. And today e-filing is the normal way of doing business. It will be the same with e-services.”

The Internal Revenue Service plans to hold a conference call on July 8 with the six largest audit firms to convince them to do more to help track the use of secret foreign bank accounts for tax evasion.

The Justice Department has filed papers seeking an order from a federal court in Miami, authorizing the Internal Revenue Service to request information from banking and financial concern UBS AG regarding U.S. taxpayers using Swiss bank accounts to evade taxes. The Justice Department is seeking permission to allow the IRS to serve a "John Doe" summons on the bank. In June, former UBS banker Bradley Birkenfeld pleaded guilty to conspiring to defraud the IRS by assisting UBS clients in avoiding U.S. reporting requirements on income in Swiss bank accounts. Birkenfeld admitted to conspiring with an American billionaire real estate developer, Swiss bankers and co-defendant Mario Staggl to help the developer evade paying $7.2 million in taxes by helping him conceal $200 million of assets in Switzerland and Liechtenstein. According to Birkenfeld,, UBS employees assisted wealthy U.S. clients in hiding offshore assets by creating sham entities and then filing IRS forms falsely claiming that the entities were the owners of the accounts. He also claimed that UBS had approximately $20 billion of assets under management in undeclared accounts for U.S. taxpayers. If approved, the summons would mandate UBS to produce records that identify U.S. taxpayers with accounts at UBS in Switzerland who elected to have their accounts remain hidden from the IRS.

The Treasury and Internal Revenue Service have issued Revenue Procedure 2008-35, TD 9409, and Reg. 121698-08, which update the rules regarding disclosure of tax return information by tax return preparers.The new rules provide an exception that allows a U.S. tax return preparer to obtain consent from a taxpayer to disclose a taxpayer's Social Security number to a non-U.S. tax return preparer when: The U.S. preparer makes the disclosure through the use of an "adequate data return safeguard;" the non-U.S. preparer receives the SSN via an "adequate data protection safeguard;" and the U.S. preparer verifies the maintenance of the adequate data protection safeguards in the request for the taxpayer's consent.

The Internal Revenue Service has moved the extended due date for partnership, estate and trust tax returns from Oct. 15 to Sept. 15 to avoid overlapping with the extended deadline for individual taxes.

H&R Block reported that its fiscal 2008 revenues rose 10 percent to $4.4 billion, thanks to growth in its tax services business and the sale of its troubled Option One mortgage unit.

The Senate has confirmed three new members of the Securities and Exchange Commission by unanimous consent, restoring the SEC to its full strength of five members.

A committee of tax experts delivered an annual report to Congress recommending improvements in the IRS's Web and electronic filing services, including one suggestion that would punish tax preparers who don't file individual returns electronically.