Congress repealed a widely criticized expansion of Form 1099 information reporting that would have applied to most payments by businesses and a similar requirement for recipients of real estate rental income. The Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (HR 4) passed the Senate
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TOPICS / TAX
IRS practice & procedure
IRS Wins Historic Credit Fund Appeal
The Fourth Circuit Court of Appeals ruled against the taxpayers in Virginia Historic Tax Credit Fund 2001 LLP v. Commissioner (docket no. 10-1333), reversing the Tax Court. As noted in Tax Matters coverage (April 2011, page 52) of the Tax Court’s holding in Historic Boardwalk Hall LLC v. Commissioner, 136
Tax Court Gives Some Petitioners Extra Time to File Motions to Vacate
During the transition to its new eAccess electronic document management system, the Tax Court failed to serve a small number of petitioners with paper or electronic notices of the documents concluding their cases (such as final decisions or orders of dismissal). The Tax Court has notified petitioners in those cases,
Tax Court Rejects Taxpayer’s Argument That Denial of Accounting Method Change Was Arbitrary
The Tax Court held that the IRS’ rejection of a taxpayer’s accounting method change request was not the result of an “automatic rejection policy” and that the IRS acted within its proper discretion in denying the request (Lattice Semiconductor Corp. v. Commissioner, TC Memo 2011-100). The taxpayer produced electronic components
IRS Responds to AICPA Accounting Software Examination Letter
In a March 29 letter from Patricia Thompson, chair of the AICPA’s Tax Executive Committee, to Chris Wagner, commissioner of the IRS’ Small Business/Self-Employed Division, the AICPA communicated its concerns regarding the Service’s program to request the accounting software files of certain small business taxpayers under examination; the letter cites
FinCEN Amends BSA Regs on FBAR Filings
The Financial Crimes Enforcement Network (FinCEN) issued a final rule (tinyurl.com/4tevafd) that amends the regulations under the Bank Secrecy Act (BSA) regarding Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to clarify when an account is foreign and therefore reportable as a foreign financial account and
Wagering Losses Not Deductible, Gambling Business Expenses Deductible
The Tax Court held that a taxpayer engaged in the trade or business of gambling could not deduct wagering losses in excess of his wagering gains but could deduct ordinary, nonwagering business expenses incurred while pursuing his gambling business. Section 165(d) limits losses from wagering transactions to the amount of
IRS Allows Deduction for Payments for Preferred Stock Used to Settle Bank’s Lawsuits
In a private letter ruling released on Friday, the IRS’ Office of Chief Counsel allowed a private bank catering to high-wealth individuals to deduct as ordinary and necessary trade or business expenses the payments it made to settle lawsuits arising from criminally fraudulent activities by one of the bank’s fund
IRS Extends, Modifies Program Allowing Truncated Social Security Numbers on Information Returns
The IRS announced that it is extending and modifying a pilot program designed to deter identity theft (Notice 2011-38). Under the program, which was introduced in 2009, filers of certain paper information returns are allowed to truncate the payee’s Social Security number on the payee statement. The notice extends the
President Signs Repeal of Expanded 1099 Requirements
On Thursday, President Barack Obama signed into law the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (HR 4; 1099 Act), which repeals both the expanded Form 1099 information reporting requirements mandated by last year’s health care legislation and also the 1099 reporting requirements imposed
IRS Issues Foreign Financial Account Reporting Guidance
The IRS issued a second notice giving guidance on various reporting requirements under the Foreign Account Tax Compliance Act (FATCA, part of PL 111-147) (Notice 2011-34). The notice responds to concerns raised by commenters following the issuance last August of Notice 2010-60, which contained preliminary guidance on implementation of the
Senate Approves 1099 Repeal, Sends Bill to President
The Senate on Tuesday passed legislation to repeal both the expanded Form 1099 information-reporting requirements mandated by last year’s health care legislation and also new 1099 reporting requirements imposed on taxpayers who receive rental income. The Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (HR
Final Regulations Issued on Validity, Priority of Federal Tax Liens
On Monday, the IRS published final regulations (TD 9520) that govern the validity and priority of federal tax liens under IRC § 6323. Under IRC § 6321, the federal government has an automatic lien against any person who does not pay federal tax for which they are liable after the
Supreme Court: Medical Residents Not Exempt From FICA
Resolving a circuit split and applying the Chevron standard of greater deference to Treasury regulations, the U.S. Supreme Court upheld the validity of Treasury regulations requiring full-time medical residents and their university employers to pay FICA tax. In doing so, the court announced that tax regulations should generally be accorded
AICPA Calls for Safeguards for Electronic Data Provided for IRS Exams
The AICPA called on the IRS to start a dialogue to fix what it views as an important problem for some small businesses under audit examination: providing electronic records to the IRS while protecting confidential information that is not relevant to the IRS’ request. The IRS maintains that the
IRS Issues Final Regs and Guidance on Mandatory E-Filing Requirements
The IRS issued final regulations (TD 9518) and several pieces of guidance relating to the requirement that return preparers e-file tax returns, starting this year. The final regulations adopt, with minor amendments, proposed regulations (REG-100194-10) that were published last December, and they require specified tax return preparers to e-file if
Unfair Lending Practice Settlement Does Not Result in Income to Borrower
In Chief Counsel advice, the IRS stated that adjustments to loan principal amounts under a settlement to reform unfair lending practices do not result in income to the borrower, even though the adjustments result in a reduction in the amount the borrower will pay under the loan (CCA 201112008). The
Tax Filing Season Resources—Tax Year 2010
This is the one-stop shop for all the updates you need to know for this year’s tax filing season. Find resources from the Journal of Accountancy, plus tax return checklists and tax savings tips from the AICPA, categorized by tax topic. INDIVIDUAL TAX Free File Program Expanded to Include Returns Filed
Uncertain Tax Position FAQs Posted
The IRS has posted a series of questions and answers (FAQs) about the new requirement for large corporations to report their uncertain tax positions. The seven FAQs address both reporting requirements for Schedule UTP, Uncertain Tax Position Statement, and the IRS’ policy of restraint. For the 2010 tax year, corporations
IRS Proposes Permanently Extending Period for Receiving Authorization to Disclose Return Information
The IRS on Thursday issued a proposed regulation that would permanently extend from 60 days to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees (REG-153338-09). IRC § 6103(c) authorizes the IRS to disclose a taxpayer’s returns or return
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