“Profits should be taxed where economic activities deriving the profits are performed and where value is created”—so said the leaders of the G-20 major economies as they endorsed the Organisation for Economic Co-operation and Development’s (OECD’s) global standard for automatic exchange of tax information at the G-20 summit in Brisbane,
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TOPICS / TAX
Individual income taxation
IRS fills in details of one-a-year IRA rollover rule
The IRS clarified how the recently announced change in how it interprets the statutory one-rollover-per-year rule for individual retirement arrangements (IRAs) will affect 2014 rollovers and how the rules will apply starting in 2015 (Announcement 2014-32). Sec. 408(d)(3)(A)(i) permits a tax-free rollover of funds in a taxpayer’s IRA as long
Filing season complications loom, IRS commissioner tells AICPA
The 2015 tax filing season “will be one of the most complicated filing seasons we’ve ever had,” IRS Commissioner John Koskinen said in a keynote address Tuesday to hundreds of attendees at the AICPA National Tax Conference in Washington. He also held out hope of penalty relief for taxpayers affected
Effective filing dates of returns are disputable issues of fact
The IRS’s motion for dismissal was denied in a case where determining the timeliness of a taxpayer’s refund claims depended on determining the effective filing date of the taxpayer’s returns. The Court of Federal Claims denied a motion by the IRS to dismiss a taxpayer’s refund claim for two prior
2015 inflation-adjusted items and tax tables issued
The IRS issued the annual inflation adjustments for 2015 for more than 40 tax provisions as well as the 2015 tax rate tables for individuals and estates and trusts (Rev. Proc. 2014-61). Among the inflation-adjusted amounts that have increased are the personal exemption, which increases from $3,950 in 2014 to
Pension plan limitations are increased for inflation
Taxpayers will be allowed to contribute more money to their retirement savings in 2015 under new pension plan limits announced by the IRS on Thursday. The IRS annually adjusts the limitations on pension plan contributions in cases where cost-of-living increases meet the statutory requirements for inflation adjustment. A list of
Asset protection of retirement funds after Clark
Protection for inherited IRAs and Roth IRAs is still possible after a Supreme Court decision denied their exemption from bankruptcy estates.
Final regs. allow deduction for local lodging expenses
Regulations issued on Tuesday finalize rules the IRS put into effect in 2012 allowing employees to deduct certain expenses paid or incurred for local lodging as business expenses (T.D. 9696). Normally, lodging expenses a taxpayer incurs while not traveling away from home are considered personal expenses under Sec. 262(a) and
IRS signals PPACA compliance issues for 2015
This month, the IRS made several updates to the Internal Revenue Manual (IRM) that provide insight on the notices and enforcement methods the Service will use next tax season to ensure taxpayers comply with the Patient Protection and Affordable Care Act (PPACA), P.L. 111-148. Most compliance efforts focus on the
Gain exclusion lost upon reacquisition of former principal residence
A repossession of a former principal residence pursuant to default on a contract for deed results in the partial recognition of gain previously excluded under Sec. 121. The Tax Court held that the portion of a taxpayer’s gain excluded under Sec. 121 was properly recognized when he repossessed his former
Exemption from PFIC regime for indirect ownership expanded
The IRS clarifies that shares held through a variety of tax-exempt organizations, plans, and accounts are generally excluded. On April 14, Treasury and the IRS announced they will amend the regulations under Sec. 1291 to provide that a U.S. person who indirectly owns stock of a passive foreign investment company
Inherited home triggers denial of first-time homebuyer credit
A home in which a taxpayer inherited an ownership interest was his principal residence, even though he lived there only a few months, the Tax Court holds. The Tax Court held that a home inherited by a taxpayer disqualified him from a first-time homebuyer credit for a new residence. The
Taxpayer wins partial IRA rollover contribution issue on appeal
Partially reversing the Tax Court, the Eighth Circuit holds that a taxpayer made a timely partial rollover contribution to his IRA. The Eighth Circuit held that the IRS and Tax Court improperly denied a taxpayer’s claim of a partial qualifying rollover contribution to his individual retirement account (IRA) by ignoring
Most qualified plan distributions to pay accident or health premiums are taxable
Final regulations exclude amounts to pay for disability insurance replacing retirement contributions. The IRS finalized regulations providing that distributions from qualified retirement plans to pay accident or health insurance premiums are taxable unless a statutory exclusion applies. However, arrangements where amounts are used to pay premiums for disability insurance to
IRS issues guidance on health insurance premium tax credits
The IRS issued regulations and revenue procedures Thursday addressing how to calculate the Sec. 36B premium tax credit, including how the credit is calculated in conjunction with the Sec. 162(l) deduction for health insurance premiums of self-employed individuals. The temporary regulations (T.D. 9683) also provide rules for taxpayers who are
Federal courts disagree on health care credits for federal exchanges
The appellate courts for the D. C. Circuit and the Fourth Circuit issued conflicting decisions on Tuesday regarding the availability of the Sec. 36B premium tax credit for taxpayers who purchase health insurance on exchanges set up by the federal government. The D.C Circuit held that the regulation permitting taxpayer’s
Court halts IRS regulation of contingent fees for refund claims
The U.S. District Court for the District of Columbia granted a motion of summary judgment and issued an injunction to prevent the IRS from regulating contingent fee arrangements for the preparation and filing of ordinary refund claims under Circular 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R.
One-IRA-rollover-a-year rule will be effective in 2015, IRS says
Following up on its promise earlier in the year to follow the Tax Court’s holding that the limit of one rollover per year applies on an aggregate basis and not on an IRA-by-IRA basis, the IRS withdrew a proposed regulation from 1981, Prop. Regs. Sec. 1.408-4(b)(4)(ii), which had provided otherwise
E-filing of amended returns, elimination of Form 1040X among TIGTA recommendations
Taxpayers should be allowed to use Form 1040 to amend their returns and should be able to e-file amended returns, according to recommendations made by the Treasury Inspector General for Tax Administration (TIGTA) on Wednesday (TIGTA Rep’t No. 2014-40-028). Although individual tax returns in the Form 1040 series may all
Limit on direct deposit of refunds will go into effect in 2015
In its latest attempt to fight tax refund fraud, the IRS said that, beginning in January 2015, it will impose a limit of three electronic direct deposits of tax refunds into a single financial account or prepaid debit card. Taxpayers who exceed the limit will receive the fourth and subsequent
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SPONSORED REPORT
Preparing clients for new provisions next tax season
As the 2025 filing season approaches, H.R. 1 introduces significant tax reforms that CPAs must be prepared to navigate. These legislative changes represent some of the most comprehensive tax updates in recent years, affecting both individual and corporate taxpayers. This report provides in-depth analysis and guidance on H.R. 1.
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Current developments in taxation of individuals: Part 2
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Current developments in taxation of individuals: Part 1
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