The IRS has rejected taxpayers' pleas, based on existing law, for primary purpose or incremental cost approaches in determining both the trigger for the entertainment deduction disallowance
of section 274(e)(2) and the amount of expenses that should be disallowed.
1.61-21(g), the employer satisfies the requirements for the exception to the deduction disallowance
The loss disallowance
rules of Treasury Regulations section 1.1502-20 were issued under this authority, but many question whether certain aspects of these rules have exceeded the scope of the statute.
The alternate calculation uses an income base significantly larger than the base for computing the regular tax, The difference is primarily attributable to an outdated depreciation system; an inventory calculation that penalizes companies for inflation; disallowance
of tax credits, such as R&D, work opportunity tax credit and others; as well as the cap on net operating losses and foreign tax credits.
According to COA's decision on June 13, the initial disallowances
for two projects in 2011 amounting to P2.085 million were affirmed, while the disallowances
for six other projects, also implemented in 2011, were reduced from P43.36 million to P33.06 million.
Records of the case showed that the COA-ROVIII affirmed the disallowances
of two infrastructure projects amounting to P2.08 million but reduced the number of disallowances
on the remaining six projects from P43,366,896 to P33,061,557.30.
The COA also lifted the notice of disallowance
against the LTO license plate standardization program.
291(a) (3)'s and (e)(1)(B)'s 20% interest-deduction disallowance
on certain local government bonds issued after Aug.
Hence, an enterprise first determines whether the assertion of a claim (i.e., a proposed disallowance
of the tax position) is probable.
Under the new guidelines the IRS will not settle unless taxpayers concede (agree to the disallowance
of) 100% of the claimed losses or deductions, reduced only by the amount of transaction costs up to 10% of such claimed losses or deductions.
The Tax Court upheld this disallowance
. However, on April 17, the Ninth Circuit Court of Appeals reversed the Tax Court and allowed these deductions.
failed to submit the required supporting documents for the salaries paid to COS and contractual workers, the audit body would issue a notice of suspension that could lead to a notice of disallowance
The unsettled disallowance
of P56,540.05 covered payment of "12 pieces of San Miguel Beer Ligth and 30 liters of Draft Beer consumed during Christmas celebration on December 19, 2017," state auditors revealed.
The Department of Transportation (DOTr) yesterday said it is now holding discussions to ensure that license plates from 2013 would be distributed to registered owners after the LTO received on July 17 the resolution lifting the Notice of Disallowance
(ND) from the Commission on Audit (COA), six months after the Supreme Court lifted its temporary restraining order (TRO).