(10) IRM 5.17.14.3.2: Revised title and updated section contents for clarity and continuity to ensure understanding that collection from third-party transferees is secondary to collecting directly from the taxpayer. (9) IRM 5.17.14.3.1: Revised title and updated section contents for clarity and continuity identifying direct and indirect transfer types. (8) IRM 5.17.14.3: Revised title and updated section contents for clarity and continuity specifically addressing transferee accountability and distinguishing taxpayer tax and non-tax debt that can be collected through third-parties under circumstances described in this IRM.
#Fraudulent conveyance third party update#
(7) IRM 5.17.14.2.5: Added sub-section to update section contents for accuracy, clarity, continuity, and to specifically address alter ego liability including cross-references. (6) IRM 5.17.14.2.4: Revised title and updated section contents for accuracy, clarity, continuity, and discuss nominee theory. (5) IRM 5.17.14.2.3: Revised title and updated section contents for accuracy, clarity, continuity, and discuss successor liability theory. (4) IRM 5.17.14.2.2: Revised title and updated section contents for accuracy, clarity, continuity, and discuss fiduciary liability theory. (3) IRM 5.17.14.2.1: Revised title and updated section contents for accuracy, clarity, continuity, and discuss transferee theory. Revised the section for continuity and clarity including using tables to set out the theories and cross-reference links as well as the administrative and judicial remedies. (2) IRM 5.17.14.2: Moved Third-Party Liability Overview to this section renumbering this and subsequent subsections to make room for the internal control requirements section. Sections relocated include: transferee, fiduciary, and successor liabilities as well as nominee and alter ego theories.
#Fraudulent conveyance third party manual#
(1) IRM 5.17.14.1: Revised title and added content to comply with the Internal Management Documents System, Internal Revenue Manual (IRM) internal control requirements.
This revision adds the new Internal Management Document (IMD) control section, reorganizes, and updates guidance on third party liabilities.
(1) This transmits revised IRM 5.17.14, Legal Reference Guide for Revenue Officers, Fraudulent Transfers and Transferee and Other Third Party Liability. Fraudulent Transfers and Transferee and Other Third Party Liabilityĥ.17.14 Fraudulent Transfers and Transferee and Other Third Party Liability Manual Transmittal Legal Reference Guide for Revenue Officers Section 14.
5.17.14.3.3.4 Successor Liability of a Corporation as a Transferee.5.17.14.3.3.2.2 Types of Fraud in a Fraudulent Transfer.5.17.14.3.3.2.1 Fraudulent Transfers Under Federal and State Law.5.17.14.3.3.2 Transferee Liability Based on Fraudulent Transfers ("In Equity" ).5.17.14.3.3.1 Transferee Liability Directly Imposed on the Transferee ("At Law" ).5.17.14.3.3 Establishing Transferee Liability.5.17.14.3.2 Collection from the Transferee is Secondary.5.17.14.3 Transferee Accountability in General.5.17.14.2 Third Party Liability Overview.5.17.14.1.4 Program Management and Review.5.17.14 Fraudulent Transfers and Transferee and Other Third Party Liability.
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