NY Times (April 9, 2021): The Tax Filing Deadline Was Delayed, but Read the Fine Print

Ann Carrns, in her New York Times article, discuss the need to double-check state deadlines for tax filing, as not all of them have adopted the federal deadline extension; the extension also only pertains to filing individual federal returns, not first-quarter estimated deadlines. The article, “The Tax Filing Deadline Was Delayed, but Read the Fine Print,” … Continue reading NY Times (April 9, 2021): The Tax Filing Deadline Was Delayed, but Read the Fine Print

TaxProf Blog – Mirit Eyal-Cohen: Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Measuring And Valuing Wealth For Federal Wealth Tax Reform (April 9, 2021)

Mirit Eyal-Cohen has published an article on the TaxProf Blog, titled “Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Measuring And Valuing Wealth For Federal Wealth Tax Reform” which discusses the SSRN article, titled How to Measure and Value Wealth for a Federal Wealth Tax Reform. The article begins as follows: One of the … Continue reading TaxProf Blog – Mirit Eyal-Cohen: Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Measuring And Valuing Wealth For Federal Wealth Tax Reform (April 9, 2021)

Darien Shanske: Agglomeration and State Personal Income Taxes: Time to Apportion (With Critical Commentary on New Hampshire’s Complaint Against Massachusetts) (March 31, 2021)

Darien Shanske, of University of California, Davis - School of Law, has made available for download his article, "Agglomeration and State Personal Income Taxes: Time to Apportion (With Critical Commentary on New Hampshire’s Complaint Against Massachusetts)," published in Fordham Urban Law Journal, Forthcoming. The abstract is as followed: The Supreme Court is currently considering granting certiorari in New Hampshire v. Massachusetts. … Continue reading Darien Shanske: Agglomeration and State Personal Income Taxes: Time to Apportion (With Critical Commentary on New Hampshire’s Complaint Against Massachusetts) (March 31, 2021)

Forbes: 4 Valuable Tax Planning Strategies Gay Couples Need Today (March 30, 2021)

Forbes has published an article, “4 Valuable Tax Planning Strategies Gay Couples Need Today” which not only encourages all readers to file their taxes early, but also provides useful information for LGBTQ couples to consider when they plan for their finances. The article begins as follows: Two of our good friends just got married, and … Continue reading Forbes: 4 Valuable Tax Planning Strategies Gay Couples Need Today (March 30, 2021)

Proposed Regs Issued for Foreign Persons and Partnerships Investing in Qualified Opportunity Funds (Reg-121095-19) (April 12, 2021).

The IRS released for publication in the Federal Register proposed regulations (REG-121095-19) addressing the requirements for certain foreign persons and foreign-owned partnerships investing in qualified opportunity funds (QOFs) and also providing flexibility with regard to working capital safe harbor plans. The summary for the proposed regs is as follows: This document contains proposed regulations that … Continue reading Proposed Regs Issued for Foreign Persons and Partnerships Investing in Qualified Opportunity Funds (Reg-121095-19) (April 12, 2021).

IRS urges participants of abusive micro-captive insurance arrangements to exit from arrangements (Apr. 9, 2021)

Internal Revenue Service officials urged participants in abusive micro-captive insurance arrangements to exit these transactions as soon as possible. The IRS has stepped up examinations of these arrangements and has recently won yet another case in U.S. Tax Court that such arrangements are not eligible for the tax benefits claimed. On March 10, 2021, the … Continue reading IRS urges participants of abusive micro-captive insurance arrangements to exit from arrangements (Apr. 9, 2021)

CCA 202114020 (Apr. 12, 2021): Bitcoin Cash Received as a Result of Bitcoin Hard Fork Included in Gross Income

In CCA 202114020, the IRS ruled on the issue of whether a taxpayer who received Bitcoin Cash as a result of the August 1, 2017, Bitcoin hard fork has gross income under section 61 of the Internal Revenue Code (Code)? The IRS reached the conclusion that, yes, a taxpayer who received Bitcoin Cash as a … Continue reading CCA 202114020 (Apr. 12, 2021): Bitcoin Cash Received as a Result of Bitcoin Hard Fork Included in Gross Income

PLR 202114001: Married Couple Cannot Deduct Medical Expense of IVF Procedures (Apr. 12, 2021).

The IRS ruled that costs and fees relating to egg donation, IVF procedures and gestational surrogacy did not qualify as deductible medical expenses under Code Sec. 213. However, medical costs and fees directly attributable to the taxpayers were deductible within the limitations of Code Sec. 213, including sperm donation and sperm freezing. See PLR 202114001 by clicking … Continue reading PLR 202114001: Married Couple Cannot Deduct Medical Expense of IVF Procedures (Apr. 12, 2021).

PLRS 202114010-202114012 (Apr. 12, 2021): Trust Beneficiaries Treated as IRA Designated Beneficiaries

In three PLRs, PLRs 202114010-202114012 (Apr. 12, 2021), the IRS ruled that children who were beneficiaries of a trust were treated as designated beneficiaries of an IRA for purposes of determining the applicable distribution period under Code Sec. 401(a)(9). See PLR 202114010 by clicking here. See PLR 202114011 by clicking here. See PLR 202114012 by … Continue reading PLRS 202114010-202114012 (Apr. 12, 2021): Trust Beneficiaries Treated as IRA Designated Beneficiaries

Taxpayer Advocate Service: NTA Blog: Erroneously claiming certain refundable tax credits could lead to being banned from claiming the credits (March 29, 2021)

The National Taxpayer Advocate Blog has published an article, titled “Erroneously claiming certain refundable tax credits could lead to being banned from claiming the credits,” which discusses how taxpayers who incorrectly claimed tax credits may get banned for two years by the IRS. The abstract is as follows: Did you know the IRS has the … Continue reading Taxpayer Advocate Service: NTA Blog: Erroneously claiming certain refundable tax credits could lead to being banned from claiming the credits (March 29, 2021)

Pallav Raghuvanshi (Greenberg Traurig LLP): Corporate Tax Hikes for Biden’s Infrastructure Plan (April 2, 2021)

Pallav Raghuvanshi, of Greenberg Traurig LLP, has have made available for download his article, "Corporate Tax Hikes for Biden’s Infrastructure Plan," published in a Greenberg Traurig Alert. The abstract is as follows: On March 11, 2021, two tax reform Bills (the Stop Tax Haven Abuse Act and the No Tax Breaks for Outsourcing Act) were introduced in both the House and the Senate … Continue reading Pallav Raghuvanshi (Greenberg Traurig LLP): Corporate Tax Hikes for Biden’s Infrastructure Plan (April 2, 2021)

IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

The IRS has updated its practice unit on receipt of dividends or interest from a related controlled foreign corporation. The overview is as follows: Note: This Unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before January 1, 2026. This extension was part of … Continue reading IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

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)

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)

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)

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!

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)

Senator Bernie Sanders introduces two pieces of legislation: The 99.5% Act and The Corporate Tax Dodging Prevention Act; Practitioners View These as The Vehicles Congress + Biden Admin Will Use for Ultimate EGT and Corporate Tax Increases (Mar. 29, 2021)

On Thursday, March 25, 2021, Senator Bernie Sanders co-sponsored two pieces of legislation, which many view as the vehicles for ultimate tax increases: The the 99.5% Act and The Corporate Tax Dodging Prevention Act. The effective date provision of the 99.% Act with EGT provisions provides that it applies to transfers made after December 31, … Continue reading Senator Bernie Sanders introduces two pieces of legislation: The 99.5% Act and The Corporate Tax Dodging Prevention Act; Practitioners View These as The Vehicles Congress + Biden Admin Will Use for Ultimate EGT and Corporate Tax Increases (Mar. 29, 2021)

IRS Practice Unit on Code Sec. 965 Transition Tax Updated (Mar. 23, 2021)

The IRS has updated its practice unit on the Code Sec. 965 Transition Tax. The summary is as follows: On December 22, 2017, IRC 965 was amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97 (Tax Cuts … Continue reading IRS Practice Unit on Code Sec. 965 Transition Tax Updated (Mar. 23, 2021)