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A PFIC can ha ve any number of shar eholders and need not be contr olled, directly or indirectly, by US shareholders. For a technical expedited advice memorandum, any additional information must be submitted within 15 calendar days after the conference. If the Associate office is not advised of problems with meeting the 21-day period, or if the request is not sent promptly after the Associate office is notified of problems with meeting the 21-day period, the Service will process the case on the assumption that no further submission will be received. A . Technical advice memoranda and technical expedited advice memoranda involving Code provisions under which regulations have not been issued ordinarily are prepared for the signature of the Associate Chief Counsel with subject matter jurisdiction. Generally, before replying to the request for technical advice or technical expedited advice, the Associate office informs the taxpayer orally or in writing of the material likely to appear in the technical advice memorandum or the technical expedited advice memorandum that the taxpayer proposed be deleted but that the Service determined should not be deleted. A. Proc. Interest on State and Local Bonds, Political Subdivision, Section 141 PDF The Tax Lawyer Citation & Style Manual 2021-2022 - American Bar Association Technical Advice Memorandum 9645002 Code Sections 162 and 263 ISSUE Are "Pre-opening Costs," as defined below, associated with opening new stores required to be capitalized under 263 of the Internal Revenue Code? In section 521 cases, the Operating Division or Appeals Office must request technical advice or technical expedited advice on qualification for exemption not covered by published precedent or if non-uniformity may exist. 1111 Constitution Avenue, N.W. Applicants may also qualify with one-year of specialized experience at, or equivalent to, the grade 9 level (GS-9) working in a legal environment whereby you provided technical advice on legal requirements, conducted legal research and analysis, drafted/authored written opinions, decisions, and/or proposals on matters involving federal tax laws .

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