Tax audits

The audit concluded a year and one day after the sports authority received a letter dated April 4, 2018, informing it that the tax-exempt status of the bonds was being examined.

A fourth audit in two months fuels the perception that the IRS has launched an enforcement initiative involving the island territory.

The IRS audit of the Puerto Rico Municipal Finance Agency's $59 million in 2005 Series B Refunding Bonds is the third IRS audit of tax-advantaged bonds involving the commonwealth announced over the last six weeks.

The $11 million in tax exempt bonds that financed the construction of the K through 6 school are being paid off by the owner of the apartment building developed on part of the 1.67-acre site.

Telley Meier, IRS field operations manager for the Indian Tribal Government/Tax Exempt Bonds office, advises bond attorneys to call the examination agent if they think an audit has been erroneously selected.

“Major banking organizations have now used this abusive tax shelter scheme to illegally shelter well over $1 billion in taxable income,” said the letter by W. Mark Scott.

The U.S. Court of Appeals for the District of Columbia ordered a district judge to review four documents totaling 16 pages in an IRS Office of Professional Responsibility case file for possible release under the federal Freedom of Information Act.

Federal subsidy payments made to issuers of Build America Bonds are continuing even as Congress remains deadlocked over funding for government agencies.

The proposed settlement involves the Jan. 3 issuance of $7.3 million in transportation development refunding revenue bonds that are being used in the hope of resolving the tax audit of $9.55 million in tax-exempt bonds issued in 2009 for construction of a parking garage.

It’s unclear if monthly federal subsidy payments on Build America Bonds will be made.

Three areas are new additions to the work plan of the Tax Exempt and Government Entities Business Operating Division, IRS officials said.

The pilot program began in May, but was not officially announced by the IRS until last week.

The Internal Revenue Service has taken no action regarding tax-exempt refunding bonds that were issued for Gettysburg College in 2010, after closing an audit that appears to have been randomly initiated.

The bonds were issued by the Chester County Industrial Development Agency for West Chester University in Pennsylvania.

The 1.2-percentage point reduction will amount to $12,000 in saving on a $1 million tax settlement.

The audit could be part of an ongoing initiative by the IRS to examine refunding bonds, said a lawyer.

The IRS is focusing on $435.2 million of Series 2014A senior lien revenue refunding bonds and $75.87 million of Series 2014C second lien revenue refunding bonds.

The proposed legislation formally allows certain but not all taxpayers to have access to their IRS audit case file prior to dispute resolution hearings, ending the requirement to file a request under the Freedom of Information Act.

The proposal would allow taxpayers to have access to their IRS audit case file prior to dispute resolution hearings, ending the requirement to file requests under the Freedom of Information Act.

IRS muni regulatory priorities for 2018 include rules on bond reissuance and final rules on notice and approval of private activity bond-financed projects under TEFRA.