IRS Legal Advice: NOL Carryback After Spin-Off

The IRS Office of Chief Counsel issued Field Attorney Advice stating that a taxpayer should not be allowed to allocate cumulative income from certain subsidiaries to a successor entity after a spin-off transaction if those subsidiaries remained owned by the taxpayer. This advice clarifies that such an allocation would be an inappropriate expansion of the Separate Return Limitation Year (SRLY) limitation.

IRS Memo on Statute of Limitations for 1120F SFR

The IRS Field Attorney Advice memo clarifies that a foreign corporation that incorrectly filed as a domestic insurance company (Form 1120-PC) but should have filed as a foreign corporation (Form 1120-F) will have the same statute of limitations as the incorrectly filed return. This applies even if the IRS files the Form 1120-F under IRC § 6020(b).

IRS Legal Memo on Disclosure Statement and IRC Section 6103

The IRS issued Field Attorney Advice (FAA) GL-104768-24 addressing disclosure of partner personal information within partnership tax proceedings. The memo clarifies when sharing such information is permissible under IRC Section 6103, distinguishing between information received from outside the IRS and information generated internally.

MARAD Foreign Vessel Coastwise Trade Request - ALOLKOY

The Maritime Administration (MARAD) has received a request for the use of the foreign vessel ALOLKOY in U.S. coastwise trade. This notice serves to inform the public and solicit potential objections or comments regarding this request.

MMS Environmental Assessment for Proposed Oil and Gas Lease Sale 216

The Minerals Management Service (MMS) has issued a Notice of Preparation for an Environmental Assessment (EA) regarding proposed Oil and Gas Lease Sale 216, tentatively scheduled for March 2011. The agency is seeking public comments on significant environmental impacts and alternatives to inform the EA process.

FMCSA: Renewal of Exemptions for Hard of Hearing CMV Drivers

The Federal Motor Carrier Safety Administration (FMCSA) is renewing exemptions for 16 individuals from the hearing requirement for interstate commercial motor vehicle drivers. These exemptions allow hard of hearing and deaf individuals to continue operating CMVs in interstate commerce. The agency is requesting comments on these renewals.

FMCSA Renews Epilepsy Exemptions for CMV Drivers and Seeks Comments

The FMCSA has renewed exemptions for five individuals from the medical requirements for commercial motor vehicle drivers concerning epilepsy or conditions causing loss of consciousness. These exemptions allow individuals with a history of seizures taking anti-seizure medication to continue operating CMVs. The agency is also requesting public comments on these renewals.

FMCSA Driver Qualification Exemption Renewal Notice

The Federal Motor Carrier Safety Administration (FMCSA) is announcing the renewal of exemptions for 16 individuals from the hearing requirement for interstate commercial motor vehicle drivers. These exemptions allow hard of hearing and deaf individuals to continue operating CMVs. The agency is also requesting comments on these renewals.

FMCSA Renews Driver Exemptions for Epilepsy and Seizure Disorders

The Federal Motor Carrier Safety Administration (FMCSA) has renewed exemptions for five individuals from medical requirements related to epilepsy and seizure disorders. These exemptions allow individuals with a history of seizures taking anti-seizure medication to continue operating commercial motor vehicles in interstate commerce.

Green Rock LLC v. IRS: Notice 2017-10 Invalidated Under APA

The Eleventh Circuit affirmed a lower court ruling invalidating IRS Notice 2017-10, which identified certain syndicated conservation easement arrangements as "listed transactions." The court found the notice invalid under the Administrative Procedure Act for failing to undergo notice-and-comment rulemaking procedures. This decision impacts the IRS's ability to designate listed transactions through sub-regulatory guidance.