Legal Advice Issued by Associate Chief Counsel |
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These documents are legal advice, signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They are issued to assist Service personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. See Chief Counsel Notice CC-2007-003 (2-9-2007).
NOTE: These documents cannot be used or cited as precedent.
Number |
Release Date |
Subject |
AM 2009-003 |
02/13/2009 |
Application of Foreign Earned Income Exclusion and the Combat Zone Exclusion to Civilian Contractors Working in Combat Zones |
AM 2009-002 |
02/06/2009 |
Federal Agency Audit Program: Classification of Workers Performing Services Pursuant to Personal Services Contracts |
AM 2009-001 |
01/09/2009 |
Proper Method of Allocation and Apportionment of Prior Period Compensation Expense Deductions Under Treas. Reg. Sections 1.861-8 and 1.861-14, Temp. Treas. Reg. Sections 1.861-8T and 1.861-14T, and I.R.C. Section 199 |
AM 2008-013 |
12/19/2008 |
Professional Gambler's Wagering Losses and Business Expenses |
AM 2008-012 |
12/19/2008 |
Application of Sec. 172(f) to Costs Included in Inventory Under Sec. 263A |
AM 2008-011 |
12/12/2008 |
Reporting of Wagering Gains and Losses |
AM 2008-010 |
09/12/2008 |
Interaction of I.R.C. Section 965 and Rev. Proc. 99-32 |
AM 2008-009 |
08/29/2008 |
UK Pension Rollovers |
AM 2008-008 |
07/11/2008 |
Applicability of Section 943(c) and (h) to Certain Transactions |
AM 2008-007 |
07/04/2008 |
Dual Consolidated Losses: Application of the Exception to Foreign Use for Certain Interests in Partnerships or Grantor Trusts |
AM 2008-006 |
05/30/2008 |
Reporting Requirements Under Section 6038B |
AM 2008-005 |
05/16/2008 |
Timing of Credit for Foreign Tax Withheld from Wages |
AM 2008-004 |
03/28/2008 |
Generic Legal Advice for Section 48A |
AM 2008-003 |
02/22/2008 |
Treatment of Certain Distributions in Complete Liquidation by a REIT |
AM 2008-002 |
02/08/2008 |
Section 280C(c)(3) - Guidance on Reduced Credit for Increasing Research Activities |
AM 2008-001 |
01/25/2008 |
Dual Consolidated Losses: Reasonable Cause Requests Relating to Periods Where Assessment of Tax Under Section 6501(a) Is Not Permitted |
AM 2007-017 |
10/31/2007 |
Applicability of Section 6695A Penalty to Estate & Gift Appraisals |
AM 2007-016 |
09/25/2007 |
Application of Notice 88-108 to Section 956(a)(1) |
AM 2007-015 |
07/27/2007 |
Section 162(f) and the Character of Relator Fees under the False Claims Act |
AM 2007-014 |
07/24/2007 |
Integration of Convertible Notes with Hedges |
AM 2007-013 |
06/15/2007 |
Exception to the Three-Year Requirement for Residences for Veterans Under Section 143(d)(2)(D) |
AM 2007-012 |
06/08/2007 |
FIN 48 & Tax Accrual Workpapers |
AM 2007-011 |
05/25/2007 |
Auxiliary Power Units (APU) |
AM 2007-010 |
05/25/2007 |
Deductibility of Administrative Expenses of Bankruptcy |
AM 2007-009 |
05/11/2007 |
Application of Sections 1.461-4(d)(6)(ii) and 1.461-5 to Service Contracts |
AM 2007-008 |
04/20/2007 |
Lease-In/Lease-Out ("LILO") and Sale-In/Lease-Out ("SILO") Exit Strategy |
AM 2007-007 |
03/23/2007 |
Taxpayer Use of Section 482 and the Commensurate With Income Standard |
AM 2007-006 |
02/23/2007 |
Elections Under Section 338 With Respect to Foreign Corporate Targets |
AM 2007-005 |
02/09/2007 |
Trusts Holding Interests in a Partnership |
AM 2007-004 |
02/02/2007 |
Variable Purchase Contracts and Share Lending Agreements |
AM 2007-003 |
02/02/2007 |
Construction Allowances for Short Term Leases of Retail Space Not Subject to Sec. 110 |
AM 2007-002 |
01/26/2007 |
State Tax Credit Transfers |
AM 2007-001 |
01/12/2007 |
Qualification for FSC benefits and ETI Exclusions |
AM 2006-006 |
10/11/2006 |
Cost of Restoring Property after Casualty Loss Deduction |
AM 2006-005 |
10/13/2006 |
Subchapter S Banks and the Special Bank Rules |
AM 2006-004 |
Pulled |
Adjusted Current Earnings for Certain Mining Property; re-published as CCA 200721019. |
AM 2006-003 |
09/29/2006 |
Allocation of Capitalizable Mixed Service Costs to Ineligible Property |
AM 2006-002 |
09/29/2006 |
Allocation under Sections 338 and 1060 to Assets in a Non-Qualified Nuclear Decommissioning Fund Purchased along with a Nuclear Power Plant |
AM 2006-001 |
09/26/2006 |
Cross-Border Financial Instruments
Hybrid Debt/Equity - Equity in the U.S. |
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Page Last Reviewed or Updated: February 13, 2009