IRS Updates Practice Unit on Section 245A Dividends Received Deduction Overview (September 13, 2021)

The IRS has updated its practice unit on Partner’s Outside Basis. The overview is as follows: The Tax Cuts and Jobs Act (TCJA) transitioned the United States from a primarily deferral-based international tax system to a participation exemption system coupled with immediate taxation of certain offshore earnings. This transition was implemented through several interlocking provisions … Continue reading IRS Updates Practice Unit on Section 245A Dividends Received Deduction Overview (September 13, 2021)

NY Times: A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied (December 28, 2021)

Jesse Drucker and Maureen Farrell, in their New York Times article, discusses the tax breaks, originally aimed at small businesses, that are utilized by the ultrawealthy. Their article, “A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied”, begins as follows: This is the story of the incredible cloning tax break.In 2004, David Baszucki, fresh off a stint … Continue reading NY Times: A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied (December 28, 2021)

ProPublica: The Great Inheritors: How Three Families Shielded Their Fortune from Taxes for Generations (December 15, 2021)

Patricia Callahan, James Bandler, Justin Elliott, Doris Burke and Jeff Ernsthausen have published their article "The Great Inheritors: How Three Families Shielded Their Fortune from Taxes for Generations". The abstract is as follows: President Franklin D. Roosevelt pounded on his desk and swore.His treasury secretary had handed him a series of memos detailing the many ways the wealthy were avoiding … Continue reading ProPublica: The Great Inheritors: How Three Families Shielded Their Fortune from Taxes for Generations (December 15, 2021)

TaxProfBlog – Johnson: The Wonderful Mark-to-Market Tax (December 2, 2021)

Paul Caron has published an article on the TaxProf Blog, titled “The Wonderful Mark-to-Market Tax”, which discusses how mark-to-market taxation would tax shareholders on the annual gain from publicly traded stock even when those gains have not been reduced to cash. The article begins as follows: Whatever its role in the current U.S. budget decisions, … Continue reading TaxProfBlog – Johnson: The Wonderful Mark-to-Market Tax (December 2, 2021)

BDO USA: Senate Finance Committee Releases Updated Text of Build Back Better Act Tax Measures (December 2021)

BDO USA has published an article, “Senate Finance Committee Releases Updated Text of Build Back Better Act Tax Measures”, published on BDO USA. The abstract is as follows: Senate Finance Committee Chairman Ron Wyden (D – Ore.) on December 11 released an updated text of the tax provisions in the Build Back Better Act (H.R. … Continue reading BDO USA: Senate Finance Committee Releases Updated Text of Build Back Better Act Tax Measures (December 2021)

Robert W. Wood (Wood LLP) : Crypto IRS Reporting Rules Promise Tax Compliance—And Enforcement (December 13, 2021)

Robert W. Wood, of Wood LLP, has made available for download his article, “Crypto IRS Reporting Rules Promise Tax Compliance—And Enforcement,” published in Forbes Magazine. The abstract is as follows: The Infrastructure Investment and Jobs Act (H.R. 3684) put crypto in the crosshairs in a comprehensive way. The crypto community was outraged when the measures … Continue reading Robert W. Wood (Wood LLP) : Crypto IRS Reporting Rules Promise Tax Compliance—And Enforcement (December 13, 2021)

Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 1 (December 3, 2021)

Bob Probasco, Senior Lecturer and Director Tax Dispute Resolution Clinic, has made available for download his article, “When Is a Late Return Not Really “Late”?? – Part 1” published on the Procedurally Taxing blog. The article begins as follows: The IRS released a legal memo recently on an issue I had never thought of before.  Would a … Continue reading Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 1 (December 3, 2021)

TaxProf Blog – Paul Caron: Top Wealth in America: And Implications for Taxing the Rich (October 22, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled “Top Wealth in America: And Implications for Taxing the Rich”, which discusses Matthew Smith, Owen Zidar, and Eric Zwick's article. The article begins as follows: This paper uses administrative tax data to estimate top wealth in the United States. We assemble new data that links … Continue reading TaxProf Blog – Paul Caron: Top Wealth in America: And Implications for Taxing the Rich (October 22, 2021)

Forbes: 7 Tax-Planning Moves To Make By End Of 2021 (December 1, 2021)

Forbes has published an article, “7 Tax-Planning Moves To Make By End Of 2021,” which discusses the proactive steps business owners and individuals can make to reduce the impact of the end-of-year taxes. The article begins as follows: Wow! 2021 has been yet another wild and crazy year. Many people have seen their incomes jump … Continue reading Forbes: 7 Tax-Planning Moves To Make By End Of 2021 (December 1, 2021)

Bloomberg Tax: Senate Republicans Will Try to Restrict Biden’s IRS Audit Boost (December 7, 2021)

Bloomberg Tax discusses the possible amendments Republicans plan on making to Democrats' reconciliation package. The article begins as follows: Senate Republicans plan to offer an amendment to Democrats’ tax-and-spend plan that would bar the IRS from using tens of billions of dollars in additional funding to audit any households making $400,000 or less.The House-passed reconciliation … Continue reading Bloomberg Tax: Senate Republicans Will Try to Restrict Biden’s IRS Audit Boost (December 7, 2021)

ProPublica: These Real Estate and Oil Tycoons Avoided Paying Taxes for Years (December 7, 2021)

Jeff Ernsthausen, Paul Kiel, and Jesse Eisinger have published their article, “These Real Estate and Oil Tycoons Avoided Paying Taxes for Years.” The abstract is as follows: Here’s a tale of two Stephen Rosses.Real life Stephen Ross, who founded Related Companies, a global firm best known for developing the Time Warner Center and Hudson Yards in Manhattan, was a … Continue reading ProPublica: These Real Estate and Oil Tycoons Avoided Paying Taxes for Years (December 7, 2021)

Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 2 (December 6, 2021)

Bob Probasco, Senior Lecturer and Director Tax Dispute Resolution Clinic, has made available for download his article, “When Is a Late Return Not Really “Late”?? – Part 2” published on the Procedurally Taxing blog. The article begins as follows: And now some observations and questions about that recent IRS legal memo on an overpayment interest issue.  The … Continue reading Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 2 (December 6, 2021)

Forbes: IRS Audits: 3 Years, 6 Years Or Forever, Which Applies To You? (December 3, 2021)

Forbes has published an article, “IRS Audits: 3 Years, 6 Years Or Forever, Which Applies To You?", which discusses the statute of limitations on IRS audits. The article begins as follows:  Wouldn’t it be satisfying to say this to the IRS? “Sorry, IRS, you missed your deadline, it’s too late to audit me!” The IRS usually has … Continue reading Forbes: IRS Audits: 3 Years, 6 Years Or Forever, Which Applies To You? (December 3, 2021)

BDO USA: 2021 Year-end Tax Planning for Businesses (November 2021)

BDO USA has published an article, “2021 Year-end Tax Planning for Businesses”, published on BDO USA. The abstract is as follows: As the U.S. entered 2021, many assumed that newly elected President Joe Biden along with Democratic majorities in the House and Senate would swiftly enact tax increases on both corporations and individuals to pay … Continue reading BDO USA: 2021 Year-end Tax Planning for Businesses (November 2021)

BDO USA: 2021 Year-End Tax Planning for Individuals (November 2021)

BDO USA has published an article, “Year-End Tax Planning for Individuals”, published on BDO USA. The abstract is as follows: As we approach year end, now is the time for individuals, business owners, and family offices to review their 2021 and 2022 tax situations and identify opportunities for reducing, deferring, or accelerating tax obligations. Areas … Continue reading BDO USA: 2021 Year-End Tax Planning for Individuals (November 2021)

McDermott, Will & Emery: Tax Reform: What’s In and What’s Out (For Now) (November 22, 2021)

Max P. Biedermann and Carlyn S. McCaffrey, of McDermott, Will & Emery, have made available for download their article “Tax Reform: What's In and What's Out (For Now)”. The abstract is as follows: After more than two months of negotiations in the US Congress, a slimmed-down version of the “Build Back Better Act” narrowly passed … Continue reading McDermott, Will & Emery: Tax Reform: What’s In and What’s Out (For Now) (November 22, 2021)

Robert W. Wood (Wood LLP) : When IRS Taxes “Loans” As Income (November 16, 2021)

Robert W. Wood, of Wood LLP, has made available for download his article, "When IRS Taxes “Loans” As Income," published in Forbes Magazine. The abstract is as follows: When your uncle loans you $5,000 to tide you over, is it taxable as income? Of course not, you have to repay it. What about when the bank loans … Continue reading Robert W. Wood (Wood LLP) : When IRS Taxes “Loans” As Income (November 16, 2021)

David Hasen : Interest Deductibility Under the Income Tax (October 2021)

David Hasen, of UF Levin College of Law, has made available for download his article, "Interest Deductibility Under the Income Tax." The abstract is as follows: The tax treatment of interest expense is something of a muddle. In the earliestyears of the income tax, interest expense generally was deductible, though borrowingwas relatively uncommon and most … Continue reading David Hasen : Interest Deductibility Under the Income Tax (October 2021)

TaxNotes – Edward A. Zelinsky, The Case for Limiting the Estate and Gift Tax Charitable Deductions (October 29, 2021)

Edward A. Zelinsky has published an article on TaxNotes, titled "The Case for Limiting the Estate and Gift Tax Charitable Deductions". The article begins as follows: If enacted into law, the legislation recently approved by the House Ways and Means Committee1 would make important changes to the federal estate and gift taxes. However, that legislation omits one compelling … Continue reading TaxNotes – Edward A. Zelinsky, The Case for Limiting the Estate and Gift Tax Charitable Deductions (October 29, 2021)