CHAPTER THREE TREASURY INTERPRETATIONS. EXPECTED LEARNING OUTCOMES l Understand the following about Treasury interpretations: The different types Their.

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Presentation transcript:

CHAPTER THREE TREASURY INTERPRETATIONS

EXPECTED LEARNING OUTCOMES l Understand the following about Treasury interpretations: The different types Their level of authority How they are accessed How to determine their validity How they are cited

TYPES OF TREASURY INTERPRETATIONS l Regulations l Revenue Rulings l Revenue Procedures l Letter Rulings l Other

Treasury Regulations and Their Authority l Final l Proposed l Temporary

How to Access Regulations l Treasury Decisions (Federal Register) l Internal Revenue Bulletin l Cumulative Bulletin

Organization and Citation of Regulations l Organization by Code Section l Citation Treas. Regs xxxxx

Formats Available l Print/Paper l CD-ROM l Modem l Web

Confirming the Reliability of a Regulation l Danger of being obsolete l Check for cautions

Revenue Rulings l Code’s application to specific set of facts l Authority limited by its facts

Discovering Relevant Revenue Rulings l Through reference service l IRS Bulletin Index-Digest System

Accessing Revenue Rulings l Internal Revenue Bulletin l Cumulative Bulletin l Print or electronic

Discovering Relevant Revenue Rulings l Through reference service l IRS Bulletin Index-Digest System

Citing a Revenue Ruling l Rev. Rul , CB 200 l Rev. Rul , IRB , 30 l Rev. Rul , CB 30

Ensuring the Reliability of a Revenue Ruling l Citating

Revenue Procedures l Procedural guidelines l Authoritative if current

Discovering Relevant Revenue Procedures l Through reference service l IRS Bulletin Index-Digest System

Accessing Revenue Procedures l Internal Revenue Bulletin l Cumulative Bulletin l Print or electronic

Citing a Revenue Procedure l Rev. Proc , CB 200 l Rev. Proc , IRB , 30 l Rev. Proc , CB 30

Ensuring the Reliability of a Revenue Procedure l Citating

Letter Rulings/Technical Advice Memoranda l Similar to Revenue Rulings l Generated through request or internal confusion l Limited authority

Discovering Relevant Letter Rulings l Cannot depend on reference services l Searching using electronic database

Citing a Letter Ruling  year 40  week 300  number in that week

Other Types of Treasury Interpretations l Determination letters l General Counsel Memos l IRS News Releases l IRS Publications l Actions on Decisions l Acquiescences/non l Internal Revenue Manual l Forms and Instructions