Coal Property Holdings, LLC: Tax Court Holds LLC Denied Charitable Contribution Deduction for Donation of Conservation Easement

The Tax Court, in Coal Property Holdings, LLC v. Commissioner, 153 T.C. No. 7 (Oct. 28, 2019), held that an LLC was not entitled to a charitable contribution deduction because the conservation purpose of the easement was not "protected in perpetuity" as required by Code Sec. 170(h)(5)(A). The Court's Abstract is as follows: In 2013 … Continue reading Coal Property Holdings, LLC: Tax Court Holds LLC Denied Charitable Contribution Deduction for Donation of Conservation Easement

IRS Issues Final regs on Life Insurance Info Reporting and Excluded Death Benefits – TD 9879

The IRS has issued final regs on the new information reporting obligations for reportable policy sales of life insurance contracts and payments of reportable death benefits under Code Sec. 6050Y, as added by the Tax Cuts and Jobs Act. The final regs also provide guidance on the amount of death benefits excluded from gross income … Continue reading IRS Issues Final regs on Life Insurance Info Reporting and Excluded Death Benefits – TD 9879

Batchelder + Kamin: Taxing the Rich: Issues and Options

Lily L. Batchelder, New York University School of Law, and David Kamin, New York University School of Law, have made available their article, Taxing the Rich: Issues and Options, distributed at the Aspen Institute Economics Strategies Group. The Abstract is as follows: The U.S. economy exhibits high inequality and low economic mobility across generations relative … Continue reading Batchelder + Kamin: Taxing the Rich: Issues and Options

Proposed Code Sec. 958 Regs + Rev. Proc. 2019-40: IRS grants relief for U.S. persons who own stock in certain foreign corporations

The Department of the Treasury and the Internal Revenue Service issued Revenue Procedure 2019-40and proposed regulations that provides relief to certain U.S. persons that own stock in certain foreign corporations. The Revenue Procedure limits the inquiries required by U.S. persons to determine whether certain foreign corporations are controlled foreign corporations ("CFCs"). The Revenue Procedure also allows certain unrelated … Continue reading Proposed Code Sec. 958 Regs + Rev. Proc. 2019-40: IRS grants relief for U.S. persons who own stock in certain foreign corporations

Taxpayer Advocate: Taxpayer Bill of Rights outlines protections for all taxpayers

The IRS notes that all taxpayers have rights when they interact with the IRS. These ten rights are the Taxpayer Bill of Rights, and they cover a wide range of topics and issues that directly affect taxpayers. These rights explain what taxpayers can expect in the event they need to work with the IRS on a … Continue reading Taxpayer Advocate: Taxpayer Bill of Rights outlines protections for all taxpayers

IRS releases new Tax Gap estimates; compliance rates remain substantially unchanged from prior study

The Internal Revenue Service today released a new set of tax gap estimates on tax years 2011, 2012 and 2013. The results show the nation's tax compliance rate is substantially unchanged from prior years. The gross tax gap is the difference between true tax liability for a given period and the amount of tax that … Continue reading IRS releases new Tax Gap estimates; compliance rates remain substantially unchanged from prior study

Schreiber, Tax Adviser: Final regs. loosen 401(k) hardship distribution requirements (Sept. 20, 2019)

Sally P. Schreiber has published her article in the Tax Adviser, Final regs. loosen 401(k) hardship distribution requirements (Sept. 20, 2019). Her article begins as follows: The IRS has amended the requirements for hardship distributions from Sec. 401(k) plans (T.D. 9875). The final regulations, issued on Friday, eliminate the requirements that plan participants take loans … Continue reading Schreiber, Tax Adviser: Final regs. loosen 401(k) hardship distribution requirements (Sept. 20, 2019)