Tier II – Extraterritorial Income Exclusion Effective Date and Transition Rules Directive #1
LMSB-Control Number: LMSB-4-0310-011
Impacted IRM 4.51.5
April 20, 2010
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MEMORANDUM FOR |
LMSB INDUSTRY DIRECTORS |
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FROM: |
Charlie Brantley |
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SUBJECT: |
Tier II – Extraterritorial Income Exclusion Effective Date and Transition Rules Directive #1 |
Change in Status
The Tier II Issue – Extraterritorial Income Exclusion Effective Date and Transition Rules have been moved from an active to monitoring status. We will continue to monitor the issue using the examination guidance provided below.
Examination Guidance
Field Personnel have guidance for examinations of Extraterritorial Income Exclusion Effective Date and Transition Rules: GLA Number AM 2007-001. When examining this issue, examiners should use the UIL codes as listed in the aforementioned guidance.
Issue guidance and support will continue through the LMSB Aerospace/Government Contracts Technical Advisor. The Aerospace/Government Contracts Technical Advisor will continue to provide assistance to the field including identification and development of the issue and, if needed, assistance with Revenue Agent Reports.
Contacts
For questions regarding the identification or development of the issue, please contact the Aerospace/Government Contracts Technical Advisor, George R. Adams, Jr. at (615) 250-6076.
This Directive is not an official pronouncement of law and cannot be used, cited or relied upon as such.
CC: Commissioner, LMSB
Deputy Commissioner, Operations
Deputy Commissioner, International
Division Counsel, LMSB
Chief, Appeals
Director, Planning, Quality, Analysis and Support
Director, Research and Workload Identification
Directors, Field Operations
