VIEWS: 6 PAGES: 2 CATEGORY: Business & Economics POSTED ON: 5/27/2010
Announcement 2008-18 sets forth a voluntary compliance initiative that encourages any foreign person who has failed to pay excise taxes due under Section 4371, or failed to disclose that it has claimed a waiver from the taxes pursuant to an income tax treaty, to become compliant with its obligations. In general, if a taxpayer participates in this initiative in accordance with the terms laid out in this announcement, the IRS will not conduct examinations covering insurance excise tax liabilities arising under the 4 situations set forth in Rev. Rul. 2008-15, or any similar fact pattern, to the extent that premiums are paid or received by the participating taxpayer during any quarterly tax period prior to October 1, 2008.
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