One of the most important bellwethers of what the IRS is thinking is the annual revenue procedure that announces the issues on which the IRS ordinarily will not rule, or never will rule, or will not rule because the issue is under study. The IRS always numbers the procedure “3” and issues it on New Year’s Day. This advisory discusses Rev. Proc. 2014-3.
The full advisory is provided on the Alston & Bird website: www.alston.com/advisories/fed-tax-feb-2014