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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In a 1988 technical advice memorandum, the IRS stated that "'member,' at the least, denotes a formal relationship in which a person, whether specifically described as a member or not, has specified rights and obligations in relation to an organization.
In technical advice memorandum 9604001, the IRS ruled that a corporate officer should be taxed on the value of cost-free insurance purchased on his behalf.
After a highly controversial decision in Technical Advice Memorandum (TAM) 9147007, which ruled that payments to the Cotton Bowl Athletic Association from its corporate sponsor were unrelated business taxable income (UBTI) under Sec.
In addition, if a Field Service Advice or Technical Advice Memorandum has been requested, the application will not be accepted.
In a technical advice memorandum (letter ruling 9549002), the IRS said capital loss carryovers that reduce current capital gains must also reduce investment income for purposes of the investment interest expense limitation of section 163(d).
In Technical Advice Memorandum (TAM) 200217009, the IRS ruled that income earned from a taxpayer's "existing patient base" following a Sec.
In addition, taxpayers may benefit from having issues raised in a broader IIR context rather than being limited to the narrow facts of an isolated technical advice memorandum or court case.
The Internal Revenue Service has issued a technical advice memorandum ruling that an employer's travel expense reimbursement plan that allowed an employee to retain frequent flier miles was taxable.
Technical Advice Memorandum (TAM) 200014010 states that there is no conclusive test of "insubstantial.
She specifically discussed an unpublished Technical Advice Memorandum made available in late April recognizing that employers can condition qualified plan eligibility on objective factors, such as whether a person was reported as an employee on the payroll records, even if this person is later reclassified as an independent contractor.
In technical advice memorandum 9521001 the Internal Revenue Service was asked if residents who pay the refundable entrance fee would be taxed on imputed interest under section 7872.
The IRS took that position in a technical advice memorandum (TAM), in which Danaher Corp.

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