technical advice memorandum

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technical advice memorandum (TAM)

A written interpretation of tax law as it relates to a specific problem posed by a specific taxpayer.The question must regard a closed transaction—a dispute over the treatment of something done in the past,not a request for advice on how to proceed in the future.Only an IRS district director or the chief of a local Appeals Office may request a TAM, which is then written by the National Office.TAMs are binding on the IRS for only the transaction at hand. Other taxpayers who use the TAM as guidance for their own actions do so at their own risk,because the IRS may take the opposite position the next time. Contrast with a private letter ruling, which has the same effect but the guidance comes from the local office and the advice relates to a future transaction. Contrast also with a revenue ruling, which is often issued in response to a particular taxpayer problem but which may be used by all other taxpayers as authority for their actions.
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The task force observed that nothing "prohibits IRS personnel from requesting both a [traditional] TAM and a Generic Legal Advice memorandum on an issue.
I told you that, Billy,' says Tam, 'but you didn't faint when I knew the President
In a recent qui tam settlement involving a nursing home, a discharged employee received $26,250 and the government recouped $150,000 based on false billings: U.
A footnote in the TAM said the IRS suggested several acceptable alternatives the taxpayer could use to render the plan accountable.
We are delighted to offer Air Canada's most loyal customers increased benefits by continuing to build our partnership with TAM, Brazil's leading airline," said Ben Smith, Air Canada's Executive Vice President and Chief Commercial Officer.
TAM and Air France strengthened their codeshare agreement to include six new Brazilian destinations.
The IRS rejected the taxpayer's argument in TAM 200337012 that his facts were distinguishable from those in Proctor, because the transfer in the TAM was pursuant to a "definitional," not a "formula," clause.
TAM, a Brazilian airline, finds offering international service requires more than just a new plane and a popular route.
The TAM was issued after the company under audit refused to change its recent written policy permitting employees to retain frequent-flier mileage accrued on business travel for their personal use.
The TAM defines assessment costs as those aneroid to determine if, and to what extent, a property is contaminated.
The Alliance Enterprise Corporation ("TaeCorp") (PINK SHEETS: AETR) is pleased to announce that it has appointed TAM Oilfield Services ("TAM"), of Khartoum, the capital of Sudan, as its representative to introduce and establish business relationships with oil and related companies interested in TaeCorp's unique landmine detection, location, mapping and removal systems and services.