Some Perspective (from an Unexpected Source) In Defense of the IRS’ Notice 2016-66

IRS Notice 2016-66 requiring dealers to file Forms 8886 to disclose Producer Owned Reinsurance Company (PORC-like activities) has created considerable uncertainty over what should be filed and by [...]


Are PORCs on the IRS’ Endangered Species List?

Just wondering if anyone has heard anything within the last few weeks about the IRS Notices regarding the status of PORCs as “abusive” tax shelters and the related filing requirements with OTSA. [...]


Head’s-Up … A Significant Filing Date for Forms 8886 Is Approaching

Almost a decade has passed since IRS activities involving PORCs (that’s Producer-Owned Reinsurance Companies) rose to a level of general awareness of automobile dealers’ CPAs. It appears the IRS [...]


Taxation of VW Settlement Payments: Don’t Expect Any Advance IRS Guidance

On February 14, I participated in a follow-up conference call / discussion hosted by Paul Metrey of NADA (Vice President, Regulatory Affairs) involving several CPA firms whose input NADA sought [...]


Court Approval of VW-Dealer Settlement Still Leaves Taxation Question Unanswered

On January 23, U.S. District Judge Court Breyer gave the Court’s final approval to the Volkswagen settlement, holding that “the settlement is fair, reasonable and adequate.” The Court evaluated [...]


Tax Return Disclosures … Is Form 8275 Indispensable?

A recent article (in Tax Notes, posted today 1/19) by two San Francisco attorneys, entitled “Tax Return Disclosures: What Is Adequate and Why It Matters,” provides a comprehensive discussion [...]


TPR Anxiety

With the recent flurry of activity regarding 2014 tax returns and the Section 263(a) Tangibles Regulations (Rev. Proc. 2015-20), I find myself feeling conflicted about what I should be doing ... [...]


Sleeper Alert! – IRS GLAM Re: Auto Dealer Facility Upgrade

Seemingly out of nowhere, the IRS released Legal Advice on the taxation of auto dealer facility image upgrade payments to dealers. It comes as no surprise that the IRS concluded that these [...]


The Sequester – Lemons Or Lemonade

One of the benefits of being at the AICPA Auto Dealership Conference is the opportunity to catch up and talk shop with many friends. While talking about how some in the press have been lamenting [...]


The Final Tangibles Regulations: Expense Or Capitalize? … At A Glance

I've seen a lot of summaries on the new / Final Tangibles Regulations that were published yesterday in the Federal Register. They all seem to basically just repeat the overview of the Regs that [...]

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