Kelly Phillips Erb, of Forbes Magazine, has made available for download her article, A Look At State Income Tax Rates In 2023—And What Else To Consider, published in Forbes. The abstract is as follows: There's been a lot of chatter about state income taxes over the past few years—thanks, in part, to the expansion of … Continue reading Forbes- Kelly Phillips Erb: A Look At State Income Tax Rates In 2023—And What Else To Consider (February 22, 2023)
Category: Tax: Income
David Biscoe Bingham (Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.): Think Twice Before You End A Trust – Income Tax Consequences of Trust Commutations and “Early Terminations”(February 24, 2023)
David Biscoe Bingham, of (Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.), has made available fordownload his article, Think Twice Before You End A Trust – Income Tax Consequences of Trust Commutations and "Early Terminations", published in JDSUPRA. The abstract is as follows: Despite the Rule Against Perpetuities (which basically says a trust can’t go on … Continue reading David Biscoe Bingham (Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.): Think Twice Before You End A Trust – Income Tax Consequences of Trust Commutations and “Early Terminations”(February 24, 2023)
Nathan Richman: Updates From IRS Criminal Investigation Deputy Chief (February 22, 2023)
Nathan Richman, of Forbes, has made available the transcript of his interview, "Updates From IRS Criminal Investigation Deputy Chief," published in Forbes. The abstract is as follows: Tax Notes legal reporter Nathan Richman talks with IRS Criminal Investigation Deputy Chief Guy Ficco about the upcoming Advance Collaboration Data Center and other CI initiatives. Click here to … Continue reading Nathan Richman: Updates From IRS Criminal Investigation Deputy Chief (February 22, 2023)
Federal Tax Crimes: Supreme Court Denies Cert in FBAR Willful Penalty Case With Justice Gorsuch Dissenting on Excessive Fines Issue (January 23, 2023)
Jack Townsend has made available for download his article, “Supreme Court Denies Cert in FBAR Willful Penalty Case With Justice Gorsuch Dissenting on Excessive Fines Issue,” published on his Federal Tax Crimes blog. The article begins as follows: I previously blogged about United States v. Toth, 33 F.4th 1 (1st Cir. 4/29./22), CA1 here and … Continue reading Federal Tax Crimes: Supreme Court Denies Cert in FBAR Willful Penalty Case With Justice Gorsuch Dissenting on Excessive Fines Issue (January 23, 2023)
Peter J Reilly (Forbes): How The Fair Tax Act Of 2023 Might Work (2/7/2023)
Peter J. Reilly, of Forbes Magazine, has made available for download his article, How The Fair Tax Act Of 2023 Might Work, published in Forbes. The abstract is as follows: The Readers Digest version of the Fair Tax Act of 2023 is that it replaces the income tax, payroll taxes that fund Social Security and … Continue reading Peter J Reilly (Forbes): How The Fair Tax Act Of 2023 Might Work (2/7/2023)
TaxNotes – Andrew Blair–Stanek, Nils Holzenberger, Benjamin Van Durme: Shelter Check: Proactively Finding Tax Minimization Strategies via AI (December 27, 2022)
Andrew Blair-Stanek, Nils Holzenberger, Benjamin Van Durme have published an article on Tax Notes, titled “Shelter Check: Proactively Finding Tax Minimization Strategies via AI.” The article begins as follows: In Peracchi,1 the Ninth Circuit addressed what basis a taxpayer had in a note in which he was the debtor. At the end of the opinion, … Continue reading TaxNotes – Andrew Blair–Stanek, Nils Holzenberger, Benjamin Van Durme: Shelter Check: Proactively Finding Tax Minimization Strategies via AI (December 27, 2022)
Jonathan H. Choi and Ariel Jurow Kleiman: Subjective Costs of Tax Compliance (February 1, 2023)
February 11, 2023 - Nicholas Ward Jonathan H. Choi and Ariel Jurow Kleiman of University of Minnesota Law School and Loyola Law School Los Angeles, respectively, have made available for download their article "Subjective Costs of Tax Compliance." The abstract is as follows: This Article introduces and estimates “subjective costs” of tax compliance, which are … Continue reading Jonathan H. Choi and Ariel Jurow Kleiman: Subjective Costs of Tax Compliance (February 1, 2023)
Forbes: State Experimentation With Wealth Taxes (January 31, 2023)
Forbes has published an article, “State Experimentation With Wealth Taxes,” which discusses the future of a federal wealth tax in tax policy. The article begins as follows: The idea of a wealth tax as a panacea for budgetary shortfalls at the federal and state levels has been around since at least the 1930s. Recently, using … Continue reading Forbes: State Experimentation With Wealth Taxes (January 31, 2023)
Bradley W. Joondeph: Remote Work and the State Taxation of Nonresident Employees (December 13, 2022)
Bradley W. Joondeph, of Santa Clara University - School of Law, has made available for download his article, “Remote Work and the State Taxation of Nonresident Employees,” published in Wisconsin Law Review, Vol. 2023, No. 3, 2023. The abstract is as follows: The onset of the COVID-19 pandemic caused millions of Americans to telecommute across … Continue reading Bradley W. Joondeph: Remote Work and the State Taxation of Nonresident Employees (December 13, 2022)
TaxProfBlog – Lesson From The Tax Court: The Meaning of ‘Business Premises’ In §119 (January 23, 2023)
Bryan Camp has published an article on the TaxProf Blog, titled “The Meaning of ‘Business Premises’ in §119,” which discusses the importance of business premise requirements in §119 of Cory H. Smith v. Commissioner, T.C. Memo. 2023-12 (Jan. 12, 2023) (Judge Toro).The article begins as follows: It’s a new year. And what better way to … Continue reading TaxProfBlog – Lesson From The Tax Court: The Meaning of ‘Business Premises’ In §119 (January 23, 2023)
TAS Tax Tip: TAS shares tips to help taxpayers prepare tax returns without issues that cause return processing errors and refund delays (December 29, 2022)
The National Taxpayer Advocate has made available for download their article, “TAS Tax Tip: TAS shares tips to help taxpayers prepare tax returns without issues that cause return processing errors and refund delays,” published in The National Taxpayer Blog. The abstract is as follows: TAS will launch a Pre-Filing Season Awareness outreach campaign in January. … Continue reading TAS Tax Tip: TAS shares tips to help taxpayers prepare tax returns without issues that cause return processing errors and refund delays (December 29, 2022)
NTA Blog: Heard Loud and Clear: IRS Postpones Implementation of $600 Form 1099-K Reporting by a Year (December 27, 2022)
The National Taxpayer Advocate has made available for download their article, “Heard Loud and Clear: IRS Postpones Implementation of $600 Form 1099-K Reporting by a Year,” published in The National Taxpayer Blog. The abstract and key-points are as follows: As a result of taxpayer confusion, lack of clear guidance, concerns about the existing backlog, and … Continue reading NTA Blog: Heard Loud and Clear: IRS Postpones Implementation of $600 Form 1099-K Reporting by a Year (December 27, 2022)
BDO USA: Claiming an Exemption from Self-employment Tax as a Limited Partner? Think Twice (November 29, 2022)
BDO USA has published an article, "Claiming an Exemption from Self-employment Tax as a Limited Partner? Think Twice”, published on BDO USA. The abstract is as follows: Limited partners claiming an exemption from Self-Employment Contributions Act (SECA) taxes may be putting themselves at risk – in certain circumstances. In fact, more recently, it has become … Continue reading BDO USA: Claiming an Exemption from Self-employment Tax as a Limited Partner? Think Twice (November 29, 2022)
Forbes: Pay IRS Penalties or Show Reasonable Cause (December 15, 2022)
Forbes has published an article, “Pay IRS Penalties or Show Reasonable Cause,” which discusses the components of the reasonable cause exception. The article begins as follows: Taxpayers claim that IRS penalties are not warranted for many reasons. One of the biggest and most misunderstood is the defense that a tax position was based on reasonable … Continue reading Forbes: Pay IRS Penalties or Show Reasonable Cause (December 15, 2022)
Procedurally Taxing: The California Office of Tax Appeals Weights in on Boyle and Electronically Filed Returns (December 6, 2022)
Joseph Cole, LL.M has made available for download his article, “The California Office of Tax Appeals Weights in on Boyle and Electronically Filed Returns,” published on the Procedurally Taxing blog. The article begins as follows: The Boyle Doctrine’s application to cases involving electronic filing of returns has been an issue of scholarly debate and litigation. … Continue reading Procedurally Taxing: The California Office of Tax Appeals Weights in on Boyle and Electronically Filed Returns (December 6, 2022)
BDO USA: U.S. Treasury Issues Proposed Regulations to Final Foreign Tax Credit Regulations (November 2022)
Micheal Masciangelo and Tiffany Ippolito of BDO have published an article, “U.S. Treasury Issues Proposed Regulations to Final Foreign Tax Credit Regulations” published in BDO USA. The article begins as follows: The U.S. Department of the Treasury on November 18 released proposed foreign tax credit (FTC) regulations that provide additional guidance on several key areas … Continue reading BDO USA: U.S. Treasury Issues Proposed Regulations to Final Foreign Tax Credit Regulations (November 2022)
Procedurally Taxing: Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional Nature Of Filing A Tax Court Petition (November 29, 2022)
Keith Fogg has made available for download his article, “Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional nature of Filing A Tax Court Petition,” published on Procedurally Taxing blog. The article begins as follows: Today the Tax Court ruled in Hallmark v. Commissioner, 159 T.C. No. 6 (2022) that the time period for filing … Continue reading Procedurally Taxing: Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional Nature Of Filing A Tax Court Petition (November 29, 2022)
Procedurally Taxing: Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties (November 28, 2022)
Leslie Book has made available for download his article, “Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties,” published on Procedurally Taxing blog. The article beings as follows: In Information Return Penalty Assessment Fight Coming to a Head [$] Andrew Velarde highlights a major tax procedure issue before the Tax Court. It concerns … Continue reading Procedurally Taxing: Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties (November 28, 2022)
Forbes: Conservation Easement Syndicates Outlawyering IRS (November 21, 2022)
Forbes has published an article, “Conservation Easement Syndicates Outlawyering IRS”, which discusses king made certain syndicated conservation easement transactions "listed transactions". The article begins as follows: The full Tax Court in one of its regular decisions (Green Valley Investors LLC) has dealt a blow against the IRS in its struggle with abusive syndicated conservation easements. … Continue reading Forbes: Conservation Easement Syndicates Outlawyering IRS (November 21, 2022)
TaxProf Blog – Bryan Camp: Lesson from the Tax Court: The Employer/Employee Gift Rule (November, 21, 2022)
Bryan Camp has published an article on the TaxProf Blog, titled "Lesson from the Tax Court: The Employer/Employee Gift Rule" which discusses the exclusion of income for gifts in tax law. The article begins as follows: Relationships can be messy. That is true whether they are work relationships or romantic relationships. But it is especially true for romantic … Continue reading TaxProf Blog – Bryan Camp: Lesson from the Tax Court: The Employer/Employee Gift Rule (November, 21, 2022)
Wealth Strategies Journal 