Michael Lloyd and Michael Chittenden's TIN Matching White Paper Published in Tax Notes Today

"Legal Authority to Expand the IRS TIN Matching Program"
Tax Notes Today
01.15.15Michael Lloyd and Michael Chittenden's white paper titled "Legal Authority to Expand the IRS TIN Matching Program" was republished in Tax Notes Today. Recently, in part, due to impending information reporting requirements of the Affordable Care Act (ACA), various stakeholders, including the IRS Information Reporting Program Advisory Committee have urged the IRS and Treasury Department to expand the IRS Taxpayer Identification Number (TIN) matching program. This white paper analyzes the current legal framework and suggests that the IRS does have the legal authority to expand the program. Ultimately, the authors conclude that "the IRS's position is not well grounded in the law and that existing statutory authority empowers the IRS to expand the Program."
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