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NewsNotes Lesli S. Laffie, J.D., LL.M. Charity Payments • IRS Grants AICPA Request • LMSB Dispute Resolution • Practitioner Hotline • Euro Use • Federal Corporate Income Tax Receipts (Chart)
From the IRS Notice 2001-78 answers questions charities have raised about the practical application of existing legal standards for distributing funds to victims of the Sept. 11, 2001 terrorist attacks. The Service recognizes the unique circumstances this tragedy caused and seeks to alleviate concerns that might otherwise delay relief to victims. Congress is considering clarifying the legislation in this area; until then, the Service has provided interim guidance to charities on payments made because of the death, injury or wounding of an individual incurred as a result of the Sept. 11, 2001 terrorist attacks. The Service will treat such payments by a charity to individuals and their families as related to the charity's exempt purpose, if the payments are made in good faith using objective standards. This administrative treatment will continue to apply to any payments made to such individuals before the earlier of final legislative action addressing these issues or Dec. 31, 2002. The Service will consider if additional guidance is needed in this area. Organizations with questions concerning this notice can contact Marvin Friedlander at (202) 283-2300.
IR-2001-109 describes the IRS's launch of a pilot program to cut the time to resolve corporate-tax disputes. The Large and Mid-Size Business Division (LMSB) Fast Track Dispute Resolution Pilot Program allows corporations to resolve outstanding issues early in the examination process. The pilot is a joint effort between LMSB and Appeals. Under the program, a taxpayer and LMSB officials can choose between two alternatives: mediation (an Appeals official will seek to facilitate communication and resolve factual issues) or dispute resolution (an Appeals official will recommend a settlement). If the parties decide to use either option, any proposed resolution must be mutually agreed on by both the taxpayer and the LMSB team manager. A corporate taxpayer does not give up any of its appeal or legal rights by participating in the program. The one-year initiative is intended to test and measure whether an expedited process (to resolve such disagreements within 120 days) reduces cost and time to the government and taxpayers. Under the existing procedure, a taxpayer's examination and appeal occur sequentially; it is not uncommon for such disputes to take two years or more to resolve. In the pilot phase, the program is available to large and mid-sized businesses that currently have at least one open year under examination and at least one disputed issue. Cases will be selected from those in which the taxpayer, Appeals and the LMSB examination team manager agree that the program might be beneficial. In addition, the pilot will require that the cases be drawn from among each of the five industry groups in LMSB. This will enable IRS officials to better ascertain the pilot's long-term potential. (For more information, see Tax Practice & Procedures: "Issue Resolution and LMSB Division Appeals," p. 50, this issue.)
Between Jan. 2 and April 2, 2002, the IRS will replace all of its practitioner hotlines and fax numbers and phase in a single, toll-free hotline. The number, (866) 860-4259, will serve as the initial contact point with the IRS for all taxpayer account issues. Hours of operation will be 7:30 a.m. to 5:30 p.m. local time (Alaska and Hawaii will be covered by Pacific Time).
Miscellaneous Jan. 1, 2002 heralded use of the euro in 12 European nations:
Although the euro has been used in electronic transactions and by banks and international businesses since January 1999, persons living, doing business or travelling in any of the 12 countries will benefit from dealing in just one currency. There are seven euro banknote denominations (five, 10, 20, 50, 100, 200 and 500); the physically larger the note, the higher the value. The euro's design is of windows and gateways on one side, symbolizing a spirit of openness. The other side features bridges, illustrating cooperation among the European nations and the rest of the world. The eight euro coins have a common side (showing the coin's value) and a national side that differs from country to country and features, for example, a head of state or unique national symbol. Like the banknotes, the coins can be used in all 12 nations, but their effects will be felt beyond the participating countries. For more information, visit www.euro.ecb.int.
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