AICPA Tax Advisor (April 8, 2021): Automatic refunds on tax-free unemployment benefits; Like-kind exchanges of real property; and More!

Sec. 1446(f) regulations: The rules and unanswered questionsBy Shan He, CPA, J.D., LL.M.; and Ben Vesely J.D., LL.M.The requirement to withhold on dispositions of interests in partnerships by foreign partners can be burdensome. Find out ways to minimize or avoid having to withhold.  IRS to automatically issue refunds on tax-free unemployment benefitsBy Sally P. Schreiber, J.D.To … Continue reading AICPA Tax Advisor (April 8, 2021): Automatic refunds on tax-free unemployment benefits; Like-kind exchanges of real property; and More!

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)

Louis Vlahos (Rivkin Radler LLP): New York Is Poised For Some Significant Tax Increases (March 30, 2021)

Louis Vlahos, of Rivkin Radler LLP, has made available for download his article, New York Is Poised For Some Significant Tax Increases, published in JDSUPRA. The abstract is as follows: Are the rich making enough of a contribution to society? Are they bearing their fair share of taxes? Many New York legislators don’t think so.Following … Continue reading Louis Vlahos (Rivkin Radler LLP): New York Is Poised For Some Significant Tax Increases (March 30, 2021)

De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution

The U.S. Tax Court in De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021), issued a “reviewed opinion” holding that economic benefits received by the taxpayer-husband under a split-dollar arrangement were not “distributions” under Code Sec. 301, but were benefits received under a compensatory arrangement and as such were taxable as “compensation … Continue reading De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution

TaxGirl: Nanny Taxes: What To Know About Being A Household Employer

John Luckenbaugh, from TaxGirl, has made available for download the Taxgirl podcast, titled "What To Know About Being A Household Employer." The abstract of the webinar is as follows: On this episode of the Taxgirl podcast, Kelly is joined by Jay Schulze, the president of HomeWork Solutions, a company that provides household employers an easy … Continue reading TaxGirl: Nanny Taxes: What To Know About Being A Household Employer

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)

Forbes: IRS Warning: FBAR Deadline For Offshore Accounts Is Still April 15 (April 9, 2021)

Forbes has published an article, “IRS Warning: FBAR Deadline For Offshore Accounts Is Still April 15,” which clarifies to readers that the April 15 deadline for those with Foreign Bank and Financial Accounts (FBAR) has not changed despite the May 17 tax filing deadline. The article begins as follows: This year’s tax filing deadline hasn’t … Continue reading Forbes: IRS Warning: FBAR Deadline For Offshore Accounts Is Still April 15 (April 9, 2021)

IRS Updates Practice Unit on When Reasonable Cause and Good Faith Exist (April 2, 2021)

The IRS has updated its practice unit discussing when reasonable cause and good faith exist and what factors should be examined. The overview is as follows: This Practice Unit supersedes the previously published Practice Unit with the same title published on July 2, 2020. The Practice Unit was updated to provide further detailed information on … Continue reading IRS Updates Practice Unit on When Reasonable Cause and Good Faith Exist (April 2, 2021)

Procedurally Taxing: Tax Court Jurisdiction When Taxpayer Late Files the Request for a Collection Due Process Hearing (March 30, 2021)

Keith Fogg, Clinical Professor of Law at Harvard Law School , discusses Ramey v Commissioner, 156 T.C. No. 1 (2021). In Ramey v Commissioner, 156 T.C. No. 1 (2021) the Tax Court determined in a precedential opinion that when the IRS issues a notice of decision rather than a notice of determination and the taxpayer has filed the collection … Continue reading Procedurally Taxing: Tax Court Jurisdiction When Taxpayer Late Files the Request for a Collection Due Process Hearing (March 30, 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)

TaxProf Blog – Paul Caron: Ordower: New York’s Proposed Mark-To-Market Tax Decouples From Federal Tax (March 25, 2021)

Paul Caron has published an article on the TaxProf Blog, titled "Ordower: New York's Proposed Mark-To-Market Tax Decouples From Federal Tax". The article begins as follows: In this article, Ordower examines proposed legislation in New York that would tax the unrealized gain and other deferred income of billionaires in the state, and the complexities that the legislation’s enactment … Continue reading TaxProf Blog – Paul Caron: Ordower: New York’s Proposed Mark-To-Market Tax Decouples From Federal Tax (March 25, 2021)

Forbes: IRS Is Catching Crypto Tax Cheats Via John Doe Summons (April 2, 2021)

Forbes has published an article, “IRS Is Catching Crypto Tax Cheats Via John Doe Summons,” which discusses potential preparation that should be aware of for taxpayers who have not properly filed their crypto taxes during the years under investigation (2016-2020). The article begins as follows: The IRS is actively hunting for crypto tax cheats by … Continue reading Forbes: IRS Is Catching Crypto Tax Cheats Via John Doe Summons (April 2, 2021)

IRS TE/GE Division Announces New Compliance Initiatives (April 5, 2021)

The IRS Tax Exempt and Government Entity (TE/GE) division issued the following news release regarding an update to its compliance program: TE/GE has updated its Compliance Program and Prioritieswebpage. This page provides information about initiatives under each of our compliance program’s six components that work together to promote compliance by tax-exempt and government entities: Compliance StrategiesData-Driven … Continue reading IRS TE/GE Division Announces New Compliance Initiatives (April 5, 2021)

Senate Finance Committee Releases Framework Proposing Changes to US International Tax System

Senate Finance Committee Chair Ron Wyden, D-Ore., Senator Sherrod Brown, D-Ohio, and Senator Mark Warner, D-Va., unveiled their framework to overhaul international taxation and invest in America by ensuring mega-corporations pay their fair share. The framework details an overhaul of three taxes Republicans created in their 2017 bill: Global Intangible Low-Taxed Income (GILTI), Foreign Derived Intangible Income … Continue reading Senate Finance Committee Releases Framework Proposing Changes to US International Tax System

Forbes: Breaking Down The Tax Provisions Of The American Rescue Plan Act (March 23, 2021)

Forbes has published an article, “Breaking Down The Tax Provisions Of The American Rescue Plan Act,” which unfolds an episode from Tax Notes Talk that discusses the impact of the new coronavirus relief package with Martin A. Sullivan and Tynisa Gaines. The article begins as follows: David Stewart: Welcome to the podcast. I'm David Stewart, editor … Continue reading Forbes: Breaking Down The Tax Provisions Of The American Rescue Plan Act (March 23, 2021)

Emily Cauble: Questions the IRS Will Not Answer (March 23, 2021)

Emily Cauble, of DePaul University - College of Law, has made available for download her article, "Questions the IRS Will Not Answer," published in the Indiana Law Journal, Vol. 97 (forthcoming). The abstract is as followed: When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer can request a … Continue reading Emily Cauble: Questions the IRS Will Not Answer (March 23, 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)

Federal Tax Crimes: Another Failed Judicial Contest of the FBAR Willful Penalty (March 23, 2021)

Jack Townsend, in his Federal Tax Crimes Blog, discusses the failed attempt to overturn the FBAR civil penalty in Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21). In Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21), TN here, in an appeal from an adverse holding in a refund suit, the Court sustained the … Continue reading Federal Tax Crimes: Another Failed Judicial Contest of the FBAR Willful Penalty (March 23, 2021)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing (March 29, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing” which discusses the outcomes of American Limousines, Inc. v. Commissioner, T.C. Memo. 2121-36 (Mar. 25, 2021) (Judge Halpern) as they pertain to owners of S corporations. The article begins as … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Failing Business No Reason To Stop Collection In CDP Hearing (March 29, 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)