Jack Townsend has made available for download his article, “Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct”, published on his Federal Tax Crimes blog. The abstract is as follows: DOJ announced indictments in a press release, here, titled as follows: Tax Attorneys and Insurance Agent Indicted for Promoting and Selling Fraudulent Tax Shelter. The indictment … Continue reading Federal Tax Crimes: Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct (November 18, 2022)

KPMG has made available for download their article, “Proposed foreign tax credit regulations”, which discusses additional guidance relating to the foreign tax credit (FTC). The abstract is as follows: On November 18, 2022, the U.S. Treasury Department and IRS (collectively, “Treasury”) released proposed regulations [PDF 371 KB] (REG-112096-22) (“2022 Proposed Regulations”) that provide additional guidance relating to the … Continue reading KPMG Report: Proposed foreign tax credit regulations (November 21, 2022)

KPMG has issued a report on preliminary observations regarding the potential tax legislative agenda in the next Congress. It’s summary begins as follows:  Election Day in the United States was November 8, 2022. All seats in the U.S. House of Representatives and around a third of the seats in the U.S. Senate were in play. … Continue reading KPMG: U.S. congressional elections and tax policy: preliminary observations (November 18, 2022)

John A. Townsend of University of Houston Law Center, has made available for download his article, Federal Tax Procedure (2022 Practitioner Ed.), published in SSRN. The abstract is as follows: Federal Tax Procedure is a book originally prepared for a course on Tax Procedure taught by Adjunct Professor Townsend at the University of Houston School … Continue reading John A. Townsend: Federal Tax Procedure (2022 Practitioner Ed.)(August 3, 2022)

Andrea Darling de Cortes, Chad M. Vanderhoef, and Alexander R. Olama of Holland & Knight LLP, have made available for download their article, "Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification" published as a Holland & Knight Alert. The article begins as follows: In Flint v. United States, 2022 WL 3593826 (Fed. Cl. … Continue reading Holland & Knight Alert: Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification (September 1, 2022)

Charles Rubin, of Rubin on Tax, has made available for download his article, “Landmark Florida Supreme Court Decision on Homestead Protections Has Been Written Out of the Law by Two Appellate Courts, and No One Appears to Have Noticed”, published on Rubin on Tax. The abstract is as follows: In Havoco of America, Ltd. v. Hill, … Continue reading Rubin on Tax: Landmark Florida Supreme Court Decision on Homestead Protections Has Been Written Out of the Law by Two Appellate Courts, and No One Appears to Have Noticed (August 28, 2022)

KPMG is reporting the following: Legislative text and a summary of the bill were released on July 27, 2022.  Senator Joe Manchin (D-WV) late July 27, 2022, announced that he had reached an agreement with Senate Majority Leader Chuck Schumer (D-NY) on tax, climate change, energy, and health care provisions to be included in the Inflation Reduction … Continue reading KPMG: Reported agreement on Senate reconciliation bill, legislative text and summary of bill after Manchin Agreement (July 27, 2022)

KPMG has made available for download their article, "JCT report on tax incentives for residential real estate, ahead of Senate Finance hearing", which contains the JCT report "JCX-16-22". The article begins as follows: The Senate Committee on Finance has scheduled a public hearing for July 20, 2022, entitled “The role of tax incentives in affordable … Continue reading KPMG: JCT report on tax incentives for residential real estate, ahead of Senate Finance hearing (July 18, 2022)

Charles Rubin, of Rubin on Tax, has made available for download his article, “Time Period to File Estate Tax Return to Make Portability Election Extended to 5 Years”, published on Rubin on Tax. The abstract is as follows: If a spouse dies and his/her estate does not fully use the decedent's remaining unified credit, the … Continue reading Rubin on Tax: Time Period to File Estate Tax Return to Make Portability Election Extended to 5 Years (July 10, 2022)

KPMG has made available for download their article, "New York State: Appeals court holds vacation home is not permanent place of abode", which discusses the case Matter of Nelson Obus v. New York State Tax Appeals Tribunal, No. 533310. The summary begins as follows: Under New York law, a non-domiciliary may be considered a New … Continue reading KPMG: New York State: Appeals court holds vacation home is not permanent place of abode (July 1, 2022)

Robert B. Wynne and Alexia L. Faraguna of McGuireWoods LLP, have made available for download their article, “IRS Announces New Audit Program for Retirement Plans,” published on McGuireWoods’s website. The abstract is as follows: On June 3, 2022, the IRS announced it is launching a pilot pre-examination retirement plan compliance program, which generally will be effective … Continue reading Robert B. Wynne and Alexia L. Faraguna (McGuireWoods LLP): IRS Announces New Audit Program for Retirement Plans (June 7, 2022)

Ed Zollars, of Kaplan Financial Education, has published an article "Charitable Deduction Disallowed for Failure to Meet Contemporaneous Written Acknowledgment Rules". The article begins as follows: A taxpayer found her deduction for a donation of property to a museum was denied entirely for failing to meet the substantiation requirements of IRC §170(f)(8)(B) in the case … Continue reading Kaplan Financial Education: Charitable Deduction Disallowed for Failure to Meet Contemporaneous Written Acknowledgment Rules (May 26, 2022)

Jay A. Soled and Richard Schmalbeck, of Rutgers University and Duke University School of Law, have made available for download their article, Substance Over Form in Transfer Tax Adjudication, published in Loyola of Los Angeles Law Review. The abstract is as follows: The elevated exemption level under the federal transfer tax system (now in excess … Continue reading Jay A. Soled and Richard Schmalbeck: Substance Over Form in Transfer Tax Adjudication (May 20, 2022)

IRS has released a Youtube video on the “ABLE Accounts”. The video shares how you can save money with disability-related expenses by having an ABLE account. https://www.youtube.com/watch?v=P7dO63wVCd8

Allison Rimm has published her Harvard Business Review article, “Taming the Epic To-Do List”. The summary of the article is as follows: The to-do list can be an indispensable tool when used to mindfully manage your time. But used indiscriminately, you become its servant. To get control of your priorities, you actually need three lists and a … Continue reading HBR: Taming the Epic To-Do List (March 26, 2018)

R&D credit's interplay with the employee retention creditBy Randy Crabtree, CPAMuch confusion surrounds the rules governing which wages can be used to claim the ERC and R&D tax credits. IRS audit rates decreased most for wealthy, GAO findsIn a study, the US Government Accountability Office finds that the IRS's individual tax audit rates decreased by … Continue reading AICPA Tax Insider (May 26, 2022): R&D credit’s interplay with the employee retention credit, IRS audit rates decreased most for wealthy, GAO finds; and More!