IRS and Tax-Exempt Entities: Interpreting Listed Transactions

The IRS and Tax-Exempt and Government Entities division are in charge of defining and issuing regulations on how taxpayers disclose certain transactions when filing tax returns which require taxpayers to include Form 8886 (disclosure statement) as part of their return.  Failure to disclose such reportable transactions may result in penalties and interest for the taxpayer if not abiding by such regulations. It is incumbent upon such qualifying tax-exempt taxpayers to review Form 8886 instructions and pay special attention to all IRS notices and/or published guidance which may affect the tax-exempt entities’ remedial efforts to correct discrepancies when using Employee Plans for tax-favored reasons to provide retirement benefits to employees.

 

Read more about what not to do when utilizing the Employee Plans Compliance Resolution System (EPCRS) as provided by the IRS when identifying what could be considered a “listed transaction” for purposes of tax avoidance. This self-correction tool also provides for the opportunity to correct the errors without IRS involvement, correction with IRS involvement/approval and correction of audit closing agreements under Audit CAP.

 

To find out more about how Wilson Tax Law Group, APLC, could help you or your business with tax litigation and strengthen your defense strategies, we invite you to set up a  consultation with our firm.

 

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense.  Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board.  Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

 

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

 

Tel: (949) 397-2292 (Newport Beach Office) 

 

Tel: (714) 463-4430 (Yorba Linda Office)