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IRS plans to issue more guidance in its pursuit of more transparency on uncertain tax positions, Commissioner Shulman says. He says the new IRS schedule for reporting uncertain tax positions is not intended as a list of issues for which deficiencies will always be established. Adding lists of frequently asked questions to the IRS website is one “good example” of the approach the government is taking to implement the large quantity of tax provisions included in recently enacted legislation, says Emily McMahon, deputy assistant treasury secretary for tax policy. John Harrell, senior counsel in Treasury's Office of Tax Counsel, says the government is working to put out expedited guidance on recently enacted provisions intended to stop the abusive use of total return swaps to avoid tax. IRS is unlikely to put out near-term guidance on the new codification of the economic substance doctrine unless the tax community makes a strong case for issues it needs addressed, says Mark Perwien, IRS special counsel to the associate chief counsel (financial institutions and products).
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