KPMG: Sixth Circuit: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers (January 7, 2022)

KPMG reports that the Sixth Circuit affirmed the judgment of the district court and held that the summonses were issued in aid of the IRS’s collection efforts and that the petitioners were not entitled to notice in Polselli v. IRS, No. 21-1010 (6th Cir. January 7, 2022). It’s summary begins as follows: The U.S. Court of Appeals … Continue reading KPMG: Sixth Circuit: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers (January 7, 2022)

KPMG: Initial analysis of final regulations concerning foreign tax credit (January 5, 2022)

KPMG has made available for download their article, “Initial analysis of final regulations concerning foreign tax credit". The abstract is as follows: Final regulations released in late December 2021 and published yesterday (January 4, 2022) in the Federal Register relate primarily to the determination of the foreign tax credit (FTC) and the allocation and apportionment … Continue reading KPMG: Initial analysis of final regulations concerning foreign tax credit (January 5, 2022)

KPMG: Foreign tax credit and certain deductions of life insurance companies (January 4, 2022)

KPMG has made available for download their article, “Foreign tax credit and certain deductions of life insurance companies (final regulations),” which raises concerns regarding the foreign tax credit and clarify rules on foreign-derived intangible income (FDII) . The abstract is as follows: Over the past several years, Treasury and the IRS have issued a series … Continue reading KPMG: Foreign tax credit and certain deductions of life insurance companies (January 4, 2022)

Customer Service at the IRS Is So Bad, Even Tax Pros Are Fed Up (January 4, 2022)

According to Bloomberg News, Tax preparer Jan Roberg rang what she calls the “bat phone”: a dedicated customer service line at the Internal Revenue Service that’s supposed to connect professionals like her to a human right away. She was put on hold, as she figured she would be. So she went to the Burger King … Continue reading Customer Service at the IRS Is So Bad, Even Tax Pros Are Fed Up (January 4, 2022)

KPMG: IRS Releases Annual Revenue Procedures for 2022 (December 31, 2021)

KPMG has made available for download their article, “IRS Releases Annual Revenue Procedures for 2021”, which discusses six of the major annual revenue procedures for 2022. The abstract is as follows: The IRS posted the first edition of the Internal Revenue Bulletin for 2022 (IRB 2022-1, dated January 3, 2022) providing six of the “annual … Continue reading KPMG: IRS Releases Annual Revenue Procedures for 2022 (December 31, 2021)

Taxpayer Advocate Service – TAS Tax Tip: Join us in January for pre-filing tax tips to make this filing season go a lot smoother (December 6, 2021)

The Taxpayer Advocate Service has published an article titled “TAS Tax Tip: Join us in January for pre-filing tax tips to make this filing season go a lot smoother”. The article begins as follows: Taxpayer Advocate offices around the country will be conducting Pre-Filing Season events in January 2022. We will share tax tips to help you … Continue reading Taxpayer Advocate Service – TAS Tax Tip: Join us in January for pre-filing tax tips to make this filing season go a lot smoother (December 6, 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)

The Economist : Why big law will keep getting bigger in the 2020s (December 27, 2021)

According to The Economist, A messy world is great news for those whose business it is to sort through a mess. One group in particular has had a fabulous time of late. “Business demand across every market has been strong,” beams Elliott Portnoy, chief executive of Dentons, the world’s fourth-biggest law firm by revenues. In 2021 … Continue reading The Economist : Why big law will keep getting bigger in the 2020s (December 27, 2021)

Procedurally Taxing: Tenancy by the Entirety and Bankruptcy Exemptions (December 16, 2021)

Keith Fogg, Clinical Professor of Law at Harvard Law, has made available for download his article, “Tenancy by the Entirety and Bankruptcy Exemptions” published on the Procedurally Taxing blog. The article begins as follows: In the case of In re Morgan, No. 21-50455 (M.D.N.C. 2021) the bankruptcy court sustained an objection by the trustee to the exemptions … Continue reading Procedurally Taxing: Tenancy by the Entirety and Bankruptcy Exemptions (December 16, 2021)

The Washington Post: The ‘Cowboy Cocktail’: How Wyoming Became One of the World’s Top Tax Havens (December 20, 2021)

The Washington Post has made available for download their article, “The 'Cowboy Cocktail': How Wyoming Became One of the World's Top Tax Havens,” which discusses Wyoming's unique laws that make it an attractive tax location. The article begins as follows: The honky-tonk bar under neon lights on the town square serves Grand Teton Amber Ale and … Continue reading The Washington Post: The ‘Cowboy Cocktail’: How Wyoming Became One of the World’s Top Tax Havens (December 20, 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)

AICPA Tax Insider (December 16, 2021): Senate Finance Committee releases tax provisions of Build Back Better Act; Build Back Better tax changes are coming … but when? and More!

Senate Finance Committee releases tax provisions of Build Back Better ActThe Senate Finance Committee's text includes changes from the House's version of the bill, including a removal of the House's increase in the SALT deduction cap. Build Back Better tax changes are coming … but when?By Edward Karl, CPA, CGMAThe Build Back Better Act contains … Continue reading AICPA Tax Insider (December 16, 2021): Senate Finance Committee releases tax provisions of Build Back Better Act; Build Back Better tax changes are coming … but when? and More!

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)

Keith Fogg (Procedurally Taxing): Tax Court Filing Update (December 14, 2021)

Keith Fogg, director of the Federal Tax Clinic at Harvard Law School’s Legal Services Center, has made available for download his article “Tax Court Filing Update”, published on the Procedurally Taxing blog. The abstract is as follows: On December 9, 2021, the Tax Court issued a news release focused on the number of petitions filed in 2021 … Continue reading Keith Fogg (Procedurally Taxing): Tax Court Filing Update (December 14, 2021)

Forbes: Tax Court Shows Some Risks of Using Self-Directed IRAs (December 14, 2021)

Forbes has published an article, “Tax Court Shows Some Risks of Using Self-Directed IRAs”, which discusses the complications that may arise from using true self-directed IRAs. The article begins as follows: True self-directed IRAs are becoming more popular among IRA owners. But the rules can be complicated and tricky. Two recent court cases show the … Continue reading Forbes: Tax Court Shows Some Risks of Using Self-Directed IRAs (December 14, 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)

TaxProfBlog – The Tax Lawyer Publishes New Issue (December 14, 2021)

Paul Caron has published an article on the TaxProf Blog, titled "The Tax Lawyer Publishes New Issue," which discusses the Vol. 75, No. 1 new issues of the Tax Lawyer. The article begins as follows: The Tax Lawyer has published Vol. 75, No. 1 (Fall 2021):Karen C. Burke (Florida), Sorting Out Partner Payments, 75 Tax Law. 1 (2021)Amandeep … Continue reading TaxProfBlog – The Tax Lawyer Publishes New Issue (December 14, 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)

TaxProfBlog – Lesson From The Tax Court : Taxpayer ‘Filed’ Return Even Though IRS Could Not Process It (December 6, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled "Lesson From The Tax Court : Taxpayer 'Filed' Return Even Though IRS Could Not Process It," which discusses James Forrest Willetts v. Commissioner. The article begins as follows: Case law gets made when things go wrong.  When things go right, a taxpayer will file … Continue reading TaxProfBlog – Lesson From The Tax Court : Taxpayer ‘Filed’ Return Even Though IRS Could Not Process It (December 6, 2021)

BDO USA: FIRPTA Rules Impact Investments in U.S. Real Property (December 2021)

BDO USA has published an article, “FIRPTA Rules Impact Investments in U.S. Real Property”, published on BDO USA. The abstract is as follows: The Foreign Investment in Real Property Tax Act (FIRPTA) was enacted in 1980 to provide an exception to the capital gain sourcing rules with respect to foreign corporations’ or nonresident aliens’ gains … Continue reading BDO USA: FIRPTA Rules Impact Investments in U.S. Real Property (December 2021)