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)

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).

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)

Forbes: The $1,100 Per Child Tax Rebate Bonus For Divorced And Unmarried Parents (February 27, 2021)

Forbes has published an article, "The $1,100 Per Child Tax Rebate Bonus For Divorced And Unmarried Parents," which discusses divorced and never married co-parents can claim an extra $1,100 per dependent child in the 2020 returns. The article begins as follows: Divorced and never married co-parents have the chance to pick up an extra $1,100 … Continue reading Forbes: The $1,100 Per Child Tax Rebate Bonus For Divorced And Unmarried Parents (February 27, 2021)

PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

In PLRs 202109002 and 202109003, the Service ruled that t certain annuity contract investment advisory fees are not treated as amounts received by the contract owner for Code Sec. 72(e) purposes. The taxpayers were insurance companies offering non-qualified deferred annuity contracts. The IRS stated observed that the fees, which were integral to the contracts, did … Continue reading PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

TD 9926: Corrected Final Regs Re Tax Withholding for Foreign Persons Disposing of US Partnership Interests (Mar. 8, 2021)

Treasury and the IRS issued corrections to final regs on withholding of tax and information reporting for certain dispositions of interests in partnerships engaged in a US trade or business. To see corrected final regs, click TD 9926: Corrected Final Regs Re Tax Withholding for Foreign Persons Disposing of US Partnership Interests (Mar. 8, 2021).

Taxpayer Advocate Service: Wait, When Did This Virtual Currency Question Appear on My 1040 Tax Form? (March 3, 2021)

The National Taxpayer Advocate Blog has published an article, titled “New NTA Blog: Wait, When Did This Virtual Currency Question Appear on My 1040 Tax Form?,” which explains the new virtual currency question on the 2020 tax return and how tax filers can approach this questio . The article begins as follows: Are you one … Continue reading Taxpayer Advocate Service: Wait, When Did This Virtual Currency Question Appear on My 1040 Tax Form? (March 3, 2021)

Procedurally Taxing: No Notice to Taxpayer Required When Summons Issued to Aid in Tax Collection (March 2, 2021)

Leslie Book, Professor of Law at the Villanova University Charles Widger School of Law, discusses Marra v US. Who can bring a petition to quash a summons that the IRS has issued when it is trying to get information that would allow it to collect on an assessed tax? This is the issue in Marra v … Continue reading Procedurally Taxing: No Notice to Taxpayer Required When Summons Issued to Aid in Tax Collection (March 2, 2021)

The Wall Street Journal: Some Democratic Lawmakers Push for Wealth Tax on New York Billionaires (February 18, 2021)

The Wall Street Journal has published an article, "Some Democratic Lawmakers Push for Wealth Tax on New York Billionaires," which discusses New York state lawmakers' new income tax collection plan. The article begins as follows: New York state lawmakers are considering an unprecedented form of wealth tax as they search for revenues to plug a budget … Continue reading The Wall Street Journal: Some Democratic Lawmakers Push for Wealth Tax on New York Billionaires (February 18, 2021)

IRS Practice Unit: Qualified Dividends and Capital Gains Rate Differential Adjustments (Jan. 4, 2021)

The IRS has released an updated practice unit on Qualified Dividends and Capital Gains Rate Differential Adjustments. The abstract is as follows: The United States (U.S.) taxes its individual residents and citizens on their worldwide income. To prevent double taxation, U.S. taxpayers are allowed a credit for foreign income taxes “paid or accrued” on income … Continue reading IRS Practice Unit: Qualified Dividends and Capital Gains Rate Differential Adjustments (Jan. 4, 2021)

Steve Gorin + Laura Duncan, Fiduciary Income Tax Refresher + 2021 Update Webinar (Feb. 3, 2021)

Steve Gorin + Laura Duncon, of Thompson Coburn, are hosting a complimentary webinar, entitled Fiduciary Income Tax Refresher + 2021 Update Webinar. The summary is as follows: In this webinar the presenters will discuss tax-savings tools that can be used between now and March 6 when preparing 2020 returns. The presenters will provide a top-ten … Continue reading Steve Gorin + Laura Duncan, Fiduciary Income Tax Refresher + 2021 Update Webinar (Feb. 3, 2021)

Sally P. Schreiber, J.D.: 2021 Inflation Adjustments and Tax Tables Issued (October 26, 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)

Federal Tax Crimes: Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty (10/21/20)

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)

BDO: 2020 Year-End Tax Planning For Individuals (October 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)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Why Vacation Home Losses Are Difficult To Deduct (October 5, 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)

PLR202035010: Irrevocable Trust Qualifies as See Through Trust for IRAs

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

IRS IR-2020-187 (Aug. 25, 2020): Reminder to Taxpayers- deadline to return distributions to retirement accounts is Aug. 31

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

Jones Day: IRS to Begin Examination of High-Wealth Taxpayers (July 15, 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)

IRS Tax Practice Unit: Foreign Tax Credit Limitation and Computation (July 2, 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)