IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

The IRS has updated its practice unit on liquidating distributions of a partners interest in a partnership. The overview is as follows: All partnership distributions are either current or liquidating. A liquidating distribution terminates a partner’s entire interest in the partnership. A current distribution reduces a partner’s capital accounts and basis in his interest in … Continue reading IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

Senate Finance Committee Releases Framework Proposing Changes to US International Tax System

Senate Finance Committee Chair Ron Wyden, D-Ore., Senator Sherrod Brown, D-Ohio, and Senator Mark Warner, D-Va., unveiled their framework to overhaul international taxation and invest in America by ensuring mega-corporations pay their fair share. The framework details an overhaul of three taxes Republicans created in their 2017 bill: Global Intangible Low-Taxed Income (GILTI), Foreign Derived Intangible Income … Continue reading Senate Finance Committee Releases Framework Proposing Changes to US International Tax System

Jeffrey Galvin (Downey Brand LLP): When Can California Trustees Use Trust Funds to Hire Lawyers? (March 23, 2021)

Jeffrey Galvin, of Downey Brand LLP, has made available for download his article, When Can California Trustees Use Trust Funds to Hire Lawyers?, published in JDSUPRA. The abstract is as follows: Many family member trustees are uncertain about whether and to what extent they can use trust assets to obtain legal representation.  For example, when … Continue reading Jeffrey Galvin (Downey Brand LLP): When Can California Trustees Use Trust Funds to Hire Lawyers? (March 23, 2021)

Forbes: Breaking Down The Tax Provisions Of The American Rescue Plan Act (March 23, 2021)

Forbes has published an article, “Breaking Down The Tax Provisions Of The American Rescue Plan Act,” which unfolds an episode from Tax Notes Talk that discusses the impact of the new coronavirus relief package with Martin A. Sullivan and Tynisa Gaines. The article begins as follows: David Stewart: Welcome to the podcast. I'm David Stewart, editor … Continue reading Forbes: Breaking Down The Tax Provisions Of The American Rescue Plan Act (March 23, 2021)

HBR: Benjamin Artz, Amanda Goodall, & Andrew J. Oswald: If Your Boss Could Do Your Job, You’re More Likely to Be Happy at Work (December 29, 2016)

Benjamin Artz, Amanda Goodall, & Andrew J. Oswald have published their Harvard Business Review article, titled "If Your Boss Could Do Your Job, You’re More Likely to Be Happy at Work" (December 19, 2016). The article begins as follows: “People don’t quit bad jobs, they quit bad bosses,” according to an old saw. Our research suggests there’s … Continue reading HBR: Benjamin Artz, Amanda Goodall, & Andrew J. Oswald: If Your Boss Could Do Your Job, You’re More Likely to Be Happy at Work (December 29, 2016)

Steven Saraisky (Cole Schotz PC): Contested Estates – When Is The Right Time To Go To Court? (March 24, 2021)

Steven Saraisky, of Cole Schotz PC, has made available for download his article, "Contested Estates – When Is The Right Time To Go To Court?" published in JDSUPRA. The abstract is as follows: There are some instances where going to court is required or necessary.  For example, there is a specific time period to contest … Continue reading Steven Saraisky (Cole Schotz PC): Contested Estates – When Is The Right Time To Go To Court? (March 24, 2021)

President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

On March 31, 2021, President Biden announced The American Jobs Plan portion of his Build Back Better program, which contains corporate tax changes in The Made in America Tax Plan. He also announced that The American Families Plan, which will propose individual tax changes will be coming soon. See the details at the following links: … Continue reading President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

Emily Cauble: Questions the IRS Will Not Answer (March 23, 2021)

Emily Cauble, of DePaul University - College of Law, has made available for download her article, "Questions the IRS Will Not Answer," published in the Indiana Law Journal, Vol. 97 (forthcoming). The abstract is as followed: When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer can request a … Continue reading Emily Cauble: Questions the IRS Will Not Answer (March 23, 2021)

National Bureau of Economic Research: Tax Evasion at the Top of the Income Distribution: Theory and Evidence (March 2021)

John Guyton,  Patrick Langetieg,  Daniel Reck,  Max Risch & Gabriel Zucman, have made available for download their article, "Tax Evasion at the Top of the Income Distribution: Theory and Evidence," published in the NBER Working Paper Series. The abstract is as follows: This paper studies tax evasion at the top of the U.S. income distribution using IRS micro-data from … Continue reading National Bureau of Economic Research: Tax Evasion at the Top of the Income Distribution: Theory and Evidence (March 2021)

Federal Tax Crimes: Another Failed Judicial Contest of the FBAR Willful Penalty (March 23, 2021)

Jack Townsend, in his Federal Tax Crimes Blog, discusses the failed attempt to overturn the FBAR civil penalty in Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21). In Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21), TN here, in an appeal from an adverse holding in a refund suit, the Court sustained the … Continue reading Federal Tax Crimes: Another Failed Judicial Contest of the FBAR Willful Penalty (March 23, 2021)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing (March 29, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing” which discusses the outcomes of American Limousines, Inc. v. Commissioner, T.C. Memo. 2121-36 (Mar. 25, 2021) (Judge Halpern) as they pertain to owners of S corporations. The article begins as … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing (March 29, 2021)

The New York Times: Remote Work Is Here to Stay. Manhattan May Never Be the Same. (March 30, 2021)

Matthew Haag, of the New York Times, discusses how COVID-19 has affected the economy due to major changes to working location. His article begins as follows: Spotify’s headquarters in the United States fills 16 floors of 4 World Trade Center, a towering office building in Lower Manhattan that was the first to rise on the … Continue reading The New York Times: Remote Work Is Here to Stay. Manhattan May Never Be the Same. (March 30, 2021)

Taxpayer Advocate Service: NTA Blog: Did You File a Superseding Return? If So, Read On (March 24, 2021)

The National Taxpayer Advocate Blog has published an article, titled “Did You File a Superseding Return? If So, Read On,” which discusses how taxpayers who have filed superseding returns may be affected by the look-back rule and the recent changes that the IRS has made to superseding returns. The abstract is as follows: The statutory … Continue reading Taxpayer Advocate Service: NTA Blog: Did You File a Superseding Return? If So, Read On (March 24, 2021)

AICPA Tax Insider (March 25, 2021): Helping clients emerge from the pandemic; IRS postpones April 15 deadline; Erosion of nexus protection and the burden on small businesses; and More!

  Revocable trusts and the grantor's death: Planning and pitfallsBy Charles A. Barragato, Ph.D., CPAAs grantor trusts become more popular for nontax reasons, practitioners should know the opportunities and risks when a grantor dies, including making a special election that provides many benefits.    IRS postpones April 15 deadlineThe IRS announced that it is postponing the April … Continue reading AICPA Tax Insider (March 25, 2021): Helping clients emerge from the pandemic; IRS postpones April 15 deadline; Erosion of nexus protection and the burden on small businesses; and More!

Barrett Ward: This UT Student Startup Is Bringing Estate Planning Into the Digital Age (March 24, 2021)

Barrett Ward, of The University of Texas at Austin, has made available for download her article, This UT Student Startup Is Bringing Estate Planning Into the Digital Age, published in the Business & Economy segment of UT News. The abstract is as followed: Each semester, The LaunchPad at The University of Texas at Austin helps students in … Continue reading Barrett Ward: This UT Student Startup Is Bringing Estate Planning Into the Digital Age (March 24, 2021)

Forbes: Collateral Attack On Charging Order Via Federal Court Fails In Kerr (March 27, 2021)

Forbes has published an article, “Collateral Attack On Charging Order Via Federal Court Fails In Kerr,” which discusses how debtors will sometimes attempt to collaterally attack a charging order and are usually futile due to abstention doctrines used in federal court. The article, which uses Kerr v. Collier, 2021 WL 972529 (N.D.Ohio, March 16, 2021) … Continue reading Forbes: Collateral Attack On Charging Order Via Federal Court Fails In Kerr (March 27, 2021)

Taxpayer Advocate Service: TAS’s Ability to Help With Delayed Refunds Is Limited (March 25, 2021)

The National Taxpayer Advocate Blog has published an article, titled “TAS’s Ability to Help With Delayed Refunds Is Limited,” which offers readers an opportunity to get assistant from the Taxpayer Advocate Service (TAS) on delayed refunds if one's case criteria is fulfilled. The article begins as follows: The Taxpayer Advocate Service (TAS) is aware that … Continue reading Taxpayer Advocate Service: TAS’s Ability to Help With Delayed Refunds Is Limited (March 25, 2021)

Jennifer Wioncek (Bilzin Sumberg LLP): For The 99.5% Act – Is Change a Coming for the Estate Planning World? (March 26, 2021)

Jennifer Wioncek, of Bilzin Sumberg LLP, has made available for download her article, "For The 99.5% Act – Is Change a Coming for the Estate Planning World?" published in JDSUPRA. The abstract is as follows: With a Democratically controlled Congress, many believe there is a chance that the reduction of the federal estate tax exemption … Continue reading Jennifer Wioncek (Bilzin Sumberg LLP): For The 99.5% Act – Is Change a Coming for the Estate Planning World? (March 26, 2021)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: S Corp Payments To Sole Shareholder Were Wages (March 22, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: S Corp Payments To Sole Shareholder Were Wages,” which discusses the outcomes of Lateesa Ward and Ward & Ward Company v. Commissioner, T.C. Memo. 2021-32 (Mar. 15, 2021) (Judge Holmes) as they pertain to owners of S corporations. The article … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: S Corp Payments To Sole Shareholder Were Wages (March 22, 2021)

Forbes: Tips For 2020 Tax Returns With IRA Distributions (March 28, 2021)

Forbes has published an article, “Tips For 2020 Tax Returns With IRA Distributions,” which discusses how retirees should correctly file their tax in particular to avoid penalty on a coronavirus-related distribution. The article begins as follows: Many retirees and people who took Covid-related retirement plan distributions might need some extra time to work through their … Continue reading Forbes: Tips For 2020 Tax Returns With IRA Distributions (March 28, 2021)