KPMG: Premium assistance and tax credit for COBRA continuation of health coverage (May 18, 2021)

KPMG is reporting that The IRS released an advance version of Notice 2021-31 as guidance regarding tax relief provided by the “American Rescue Plan Act of 2021” (Pub. L. No. 117-2, enacted March 11, 2021) for COBRA-related continuation of health coverage. Notice 2021-31 provides guidance in a “question and answer” (Q&A) format for employers, plan … Continue reading KPMG: Premium assistance and tax credit for COBRA continuation of health coverage (May 18, 2021)

IRS Notice 2021-03: Extension of Temporary Relief from the Physical Presence Requirement for Spousal Consents Under Qualified Retirement Plans

The IRS responses to the continuing public health emergency caused by the Coronavirus Disease 2019 (COVID-19) pandemic, and the related social distancing that has been implemented, this notice extends from January 1, 2021, through June 30, 2021, the temporary relief provided in Notice 2020-42, 2020-26 I.R.B. 986, from the physical presence requirement in Treasury Regulation … Continue reading IRS Notice 2021-03: Extension of Temporary Relief from the Physical Presence Requirement for Spousal Consents Under Qualified Retirement Plans

Barbara T. Kaplan and Shira Peleg (Greenberg Traurig LLP): The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers (May 12, 2021)

Barbara T. Kaplan and Shira Peleg, of Greenberg Traurig LLP, have made available for download their article, “The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers,” published in a Greenberg Traurig Alert. The abstract is as follows: Recent John Doe summonses show the IRS is expanding its use of those … Continue reading Barbara T. Kaplan and Shira Peleg (Greenberg Traurig LLP): The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers (May 12, 2021)

Rev. Proc. 2021-26: Automatic Change of Accounting Method Procedures Expanded for CFCs

The IRS has released Rev. Proc. 2021-26 which modified its automatic consent procedures in Rev. Proc. 2019-43 , I.R.B. 2019-48, 1107, to allow certain foreign corporations to change their method of accounting for deprecation to the alternative depreciation system under Code Sec. 168(g) (ADS). Additionally, terms and conditions in Rev. Proc. 2015-13 , I.R.B. 2015-5, … Continue reading Rev. Proc. 2021-26: Automatic Change of Accounting Method Procedures Expanded for CFCs

IRS Issues Overview of Tax Provisions in ARP and Tax Benefits (May 11, 2021)

The IRS provided an overview of some of the key tax provisions in the American Rescue Plan Act and encourages taxpayers with children should file returns soon for advance payments of Child Tax Credit. Several provisions affect the 2020 tax return people are filling out this filing season, including one exempting up to $10,200 in … Continue reading IRS Issues Overview of Tax Provisions in ARP and Tax Benefits (May 11, 2021)

Joint Committee On Taxation Provides Background on Taxation of High Income and High Wealth Taxpayers (May 10, 2021)

The Joint Committee on Taxation has released its publication, Present Law And Background On The Taxation Of High Income And High Wealth Taxpayers, on May 10, 2021. To download report, JCX-24-21, click: Present Law And Background On The Taxation Of High Income And High Wealth Taxpayers (May 10, 2021)

Taxpayer Advocate Service: TAS Tax Tips: Keep safe on social media at tax time – Don’t post or message tax info (May 5, 2021)

The Taxpayer Advocate Service has published an article titled “TAS Tax Tips: Keep safe on social media at tax time – Don’t post or message tax info,” which discusses ways taxpayers can protect their personal and tax account information. The article begins as follows: Waiting on your tax refund can be difficult. It can be … Continue reading Taxpayer Advocate Service: TAS Tax Tips: Keep safe on social media at tax time – Don’t post or message tax info (May 5, 2021)

Osvaldo Garcia and Jennifer Wioncek (Bilzin Sumberg): Florida’s Proposed Directed Trust and Community Property Trust Statutes: What You Need to Know (April 21, 2021)

Osvaldo Garcia and Jennifer Wioncek, of Bilzin Sumberg, have made available for download their article, “Florida's Proposed Directed Trust and Community Property Trust Statutes: What You Need to Know,” published in JDSUPRA. The abstract is as follows:  The Florida legislature is currently in the advanced stages of enacting legislation that will make critical changes to the … Continue reading Osvaldo Garcia and Jennifer Wioncek (Bilzin Sumberg): Florida’s Proposed Directed Trust and Community Property Trust Statutes: What You Need to Know (April 21, 2021)

Steve Gorin’s Business Succession Solutions (1st Qtr 2021): Business Opportunities; Taxpayer Asserts Substance Over Form; Unincorporated Entity as S Corporation

Steve Gorin, of Thompson Coburn LLP, has issued his 1st quarter business succession solutions, which include the following: Business OpportunitiesWhen do performing services and providing business opportunities avoid gift tax, and when do they generate property rights that are deemed transferred in a gift taxable transaction? For an exploration of this continuum and how developments … Continue reading Steve Gorin’s Business Succession Solutions (1st Qtr 2021): Business Opportunities; Taxpayer Asserts Substance Over Form; Unincorporated Entity as S Corporation

Texas Fiduciary Litigator: Business Divorce: Court Held That Parties Did Not Form A Partnership Where Certain Express Conditions Precedent Were Not Met (April 10, 2021)

David Fowler Johnson, in his Texas Fiduciary Litigator Blog, discusses Anubis Pictures, LLC v. Selig. The abstract is as follows: Parties often begin a business together without thinking through all of the legal details that define their rights. When they eventually divorce, they need to resort to the language in agreements that they entered into … Continue reading Texas Fiduciary Litigator: Business Divorce: Court Held That Parties Did Not Form A Partnership Where Certain Express Conditions Precedent Were Not Met (April 10, 2021)

Texas Fiduciary Litigator: Court Finds That Party Lacked Standing In A Probate Proceeding Where She Was Not An Informal Spouse (April 10, 2021)

David Fowler Johnson, in his Texas Fiduciary Litigator Blog, discusses In re Estate of Pandozy. The abstract of the webinar is as follows: In In re Estate of Pandozy, a woman attempted to intervene in a probate proceeding claiming that she was the informal spouse of the decedent. No. 05-19-00755-CV, 2021 Tex. App. LEXIS 1265 (Tex. … Continue reading Texas Fiduciary Litigator: Court Finds That Party Lacked Standing In A Probate Proceeding Where She Was Not An Informal Spouse (April 10, 2021)

IRS Reminds Taxpayers of Automatic Filing Extensions (April 29, 2021)

Anyone can request an automatic tax-filing extension, but some people get extra time without asking, according to the IRS. Due to the ongoing pandemic, this year the IRS postponed the usual April 15 deadline for filing individual income tax returns until May 17, 2021. Even so, as is the case every year, many Americans will still need … Continue reading IRS Reminds Taxpayers of Automatic Filing Extensions (April 29, 2021)

IRS provides options for gig economy workers and those with unemployment benefits (April 29, 2021)

The IRS reminds workers in the gig economy and those who claimed unemployment compensation in 2020 of their options and where to find information on meeting their tax obligations. Gig economy The gig economy refers to income earned providing on-demand work performing services or selling goods, including driving a car for booked rides or deliveries, … Continue reading IRS provides options for gig economy workers and those with unemployment benefits (April 29, 2021)

Barker v. Comm’r: Tax Court Properly Upheld Income Tax Deficiency (April 27, 2021)

In Barker v. Commissioner of Internal Revenue, No. 19-11994 (11th Cir. 2021), the Tax Court’s upholding of the IRS’s determination of an income tax deficiency (individual) was affirmed. The taxpayer started an entertainment company (partnership for tax purposes). As a passthrough entity, the company paid no income tax and its losses flow directly through to … Continue reading Barker v. Comm’r: Tax Court Properly Upheld Income Tax Deficiency (April 27, 2021)

Michael Boulware v. Cir.: No Abuse of Discretion Found in Tax Court’s Denial of Individual’s Motion for Reconsideration of Fraud Penalty (April 27, 2021)

In Michael Boulware v. Cir, No. 19-73235 (9th Cir. 2021), The Tax Court did not abuse its discretion by denying an individual's motion for reconsideration of a fraud penalty. The IRS issued two separate notices of deficiencies determining civil deficiencies in tax along with penalties for several tax years at issue. The taxpayer filed two … Continue reading Michael Boulware v. Cir.: No Abuse of Discretion Found in Tax Court’s Denial of Individual’s Motion for Reconsideration of Fraud Penalty (April 27, 2021)

Marvin A. Kirsne (Greenberg Traurig LLP): State Sales Tax on Sale of Non-Fungible Tokens (NFTs) – Questions and Answers (April 29, 2021)

Marvin A. Kirsner, of Greenberg Traurig LLP, has have made available for download his article, “State Sales Tax on Sale of Non-Fungible Tokens (NFTs) – Questions and Answers,” published in Greenberg Traurig Alert. The abstract is as follows: Non-fungible tokens (NFTs), which can be used as a medium for art, music, video clips, trading cards, and other collectibles have recently … Continue reading Marvin A. Kirsne (Greenberg Traurig LLP): State Sales Tax on Sale of Non-Fungible Tokens (NFTs) – Questions and Answers (April 29, 2021)

Haghnazarzadeh, T.C. Memo. 2021-47: Married Couple Had Unreported Income in Bank Accounts Now Owes IRS Nearly $3 Million (April 29, 2021)

The Tax Court released Memorandum Opinion for Josef Haghnazarzadeh and Catherine Y. Haghnazarzadeh v. Commissioner of Internal Revenue, T.C. Memo. 2021-47 (April 29, 2021) and announced that decision will be entered under Rule 155. A married couple had unreported taxable income for two tax years at issue. The taxpayers did not produce books or records … Continue reading Haghnazarzadeh, T.C. Memo. 2021-47: Married Couple Had Unreported Income in Bank Accounts Now Owes IRS Nearly $3 Million (April 29, 2021)

Joint Committee On Taxation Issues Reports on Securing A Strong Retirement Act Of 2021 (May 4, 2021)

The Joint Committee on Taxation has released its publication, Description Of The Chairman's Amendment In The Nature Of A Substitute To H.R.__, The "Securing A Strong Retirement Act Of 2021", on May 4, 2021. To download report, JCX-23-21, click: Description Of The Chairman's Amendment In The Nature Of A Substitute To H.R.__, The "Securing A Strong … Continue reading Joint Committee On Taxation Issues Reports on Securing A Strong Retirement Act Of 2021 (May 4, 2021)