Offer-in-compromise scams expected to increaseBy Dave Strausfeld, J.D.What can be done about predatory firms that make exaggerated promises of being able to settle tax debt? A recession provides fertile ground for their scams. 2021 inflation adjustments and tax tables issuedThe IRS issued the 2021 inflation adjustment amounts and tax tables for use in preparing 2021 … Continue reading AICPA Tax Insider (October 29, 2020): Offer-in-compromise Scams Expected to Increase; 2021 Inflation Adjustments and Tax Tables Issued; Inflation-adjusted Income Ranges for 2021 IRA and 401(k) Plans; and More!
Timothy Fitzgerald, Kevin Hassett, Cody Kallan, and Casey B. Mulligan, of Texas Tech University; Independent, University of Wisconsin - Madison, and University of Chicago; National Bureau of Economic Research (NBER), have made available for download their article, "An Analysis of Vice President Biden's Economic Agenda: The Long Run Impacts of its Regulation, Taxes, and Spending," … Continue reading Timothy Fitzgerald, Kevin Hassett, Cody Kallan, and Casey B. Mulligan: An Analysis of Vice President Biden’s Economic Agenda: The Long Run Impacts of its Regulation, Taxes, and Spending (October 21, 2020)
Sally P. Schreiber’s column in the Journal of Accountancy focuses on new inflation adjustments for tax provisions. Her article, "2021 Inflation Adjustments and Tax Tables Issued," begins as follows: The IRS on Monday issued the 2021 annual inflation adjustments for many tax provisions, as well as the 2021 tax rate tables for individuals and estates … Continue reading Sally P. Schreiber, J.D.: 2021 Inflation Adjustments and Tax Tables Issued (October 26, 2020)
Jack Townsend, in his Federal Tax Crimes Blog, discusses United States v. Horowitz, ___ F.3d ___, 2020 U.S. App. LEXIS 33074 (4th Cir. 2020). OVDP has been discontinued, but a similar risk is encountered in making the decision to join the Streamlined program which requires a certification of non-willfulness with supporting narrative facts. Streamlined was designed … Continue reading Federal Tax Crimes: Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty (10/21/20)
Paul Bonner's column in the Journal of Accountancy focuses on new IRS tax law updates. His article, Final regs. outline trust and estate expenses still deductible under TCJA, begins as follows: The IRS on Monday issued final regulations (T.D. 9918) clarifying that certain expenses incurred by, and certain excess deductions upon the termination of, an … Continue reading Paul Bonner: Final regs. outline trust and estate expenses still deductible under TCJA (September 22, 2020)
BDO has published an article, "2020 Year-End Tax Planning For Individuals," which discusses tax planning for 2020. The article begins as follows: As the year-end approaches, individuals, business owners and family offices should be reviewing their situations to identify any opportunities for reducing, deferring or accelerating tax obligations. Areas that should be looked at in … Continue reading BDO: 2020 Year-End Tax Planning For Individuals (October 2020)
Bryan Camp has published an article on the TaxProf Blog, titled Lesson From The Tax Court: Why Vacation Home Losses Are Difficult To Deduct. The article begins as follows: Tax shelters come in many forms. Some shelters are activities that have no genuine economic purpose; they exist simply to generate tax benefits. Some micro-captive insurance arrangements are a great example, as you can learn … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Why Vacation Home Losses Are Difficult To Deduct (October 5, 2020)
Sally P. Schreiber, of the Journal of Accountancy, has published her article, titled "Rules govern withholding on transfers of partnership interests and ECI." The article begins as follows: The IRS finalized regulations on the operation of Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from … Continue reading Sally P. Schreiber: Rules govern withholding on transfers of partnership interests and ECI (October 8, 2020)
Ithi Joshi, of Dunlap Bennett & Ludwig PLLC, has made available for download her article, Does my Company Lose its S-Corp Election if a Shareholder Dies?, published in JDSUPRA. The abstract is as follows: S-Corp tax treatment continues to be a popular choice for many business corporations as they seek favorable tax treatment of business income. The S-Corp status … Continue reading Ithi Joshi (Dunlap Bennett & Ludwig PLLC): Does my Company Lose its S-Corp Election if a Shareholder Dies? (September 24, 2020)
Treasury has released final regulations contenting amendments to Treas. Reg. §§1.67–4, 1.642(h)–2 and 1.642(h)–5, clarifying that the following deductions allowed to an estate or non-grantor trust are not miscellaneous itemized deductions: costs paid or incurred in connection with the administration of an estate or non-grantor trust that would not have been incurred if the property … Continue reading TD 9918: Non grantor Trusts Misc. Itemized Deductions
The IRS has issued final regulations (T.D. 9914) as guidance on the definition of an eligible terminated S corporation and rules relating to distributions of money by such a corporation after the post-termination transition period. To see final regs, click Final Regs - T.D. 9914: Eligible Terminated S Corps (Sept. 15, 2020).
In PLR 202035010, the Service ruled that an irrevocable trust qualified as a see through trust regarding IRA distributions under Reg. §1.401(a)(9)-4, Q&A-5. In PLR 202035010, the decedent ("D") established two trusts, one revocable and one irrevocable trust. D named the revocable trust as the beneficiary of his two IRAs. The revocable trust named D's … Continue reading PLR202035010: Irrevocable Trust Qualifies as See Through Trust for IRAs
The Internal Revenue Service today reminds IRA owners, beneficiaries or workplace retirement plan participants who received a Required Minimum Distribution (RMD) this year that they have until August 31 to rollover or repay the distribution to avoid paying taxes. The Coronavirus Aid, Relief, and Economic Security Act, or CARES Act, waives RMDs during 2020 for … Continue reading IRS IR-2020-187 (Aug. 25, 2020): Reminder to Taxpayers- deadline to return distributions to retirement accounts is Aug. 31
The tax matters partner of a partnership was not entitled to a charitable contribution deduction because the conservation purpose underlying the easement was not protected in perpetuity as required by Code Sec. 170(h)(5)(A). See full opinion by clicking Belair Woods, LLC v Commissioner, TC Memo 2020-112 (July 22, 2020).
Jones Day and several other sources have reported that the Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private foundations that are often established by high-income taxpayers through the Global High Wealth … Continue reading Jones Day: IRS to Begin Examination of High-Wealth Taxpayers (July 15, 2020)
The IRS has updated its tax tax practice unit (a resource on substantive topics for IRS agents) on limitations and computation of the foreign tax credit. The overview is as follows: United States (U.S.) citizens and resident aliens are subject to tax on worldwide taxable income (WWTI), which includes both U.S. source taxable income (USTI) … Continue reading IRS Tax Practice Unit: Foreign Tax Credit Limitation and Computation (July 2, 2020)
The IRS Large Business and International (LB&I) division has released a series of practice units for IRS agents, which are a resource on substantive topics for agents, on S corp distributions of accumulated earnings and profits. See the IRS Practice Units Below: Distributions with accumulated earnings & profitsGeneral overview of accumulated earnings & profits
The Treasury Department and the IRS are proposing updates to the partnership form for tax year 2021 (filing season 2022). The updates will provide greater clarity for partners on how to compute their U.S. income tax liability with respect to international tax matters, including how to compute deductions and credits. The redesigned form and instructions … Continue reading IRS News: Proposed International Changes to Form 1065, U.S. Return of Partnership Income for Tax Year 2021
Treasury and the IRS have published a correcting amendment to final regulations related to foreign partners for effectively connected taxable income on June 11, 2020. The summary for the amendment is as follows: This document contains corrections to Treasury Decision 9394, which was published in the Federal Register on Tuesday, April 29, 2008. Treasury Decision 9394 contained … Continue reading TD 9394: Correcting amendment to final regulations: Withholding related to foreign partners for effectively connected taxable income (June 11, 2020).
The U.S. Treasury Department and IRS have released a notice of proposed rulemaking (REG-118997-19) that is intended to clarify the definition of a “qualifying relative” for purposes of various Code provisions for tax years 2018 through 2025. With the release, part of the regulations proposed in January 2017, that address the support test for a … Continue reading Proposed Regs Issued Clarifying Definition of “Qualifying Relative” and personal exemption amount