By: Amanda Wilson If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including foreign...

By: Amanda Wilson The IRS has released yet another private letter ruling (Letter 201522002) in the REIT area. This time, the IRS addressed the REIT treatment of income from the rental of outdoor advertising space (i.e., billboards). At issue were...

By: Amanda Wilson If you are about to file a Form 3115 requesting a change in accounting method, you should be aware that the IRS released new guidance yesterday in the form of Revenue Procedure 2015-33. This new revenue procedure modifies the...

By: Amanda Wilson The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically, the IRS may hit pause on these...