Purported loans to a startup are ruled equity; a worthless debt claim is held inapplicable.
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TOPICS
Tax
IRS permits same-sex couples to recalculate marital exclusion amounts
Recalculations of transfers not qualifying solely because of the Defense of Marriage Act are not restricted by the statute of limitation.
IRS enforcement activities dropped in 2016
The IRS reported several large drops in its enforcement activities in fiscal year 2016, including a 16% drop in audits, a 40% drop in levies, and a 9% drop in liens compared to the prior year.
Hot jobs: Tax managers in high demand
“Tax manager” is one of the top high-demand positions on a “hot jobs” list distributed by global outplacement and executive coaching firm Challenger, Gray & Christmas.
Use of driver’s license numbers raises security concerns
The decision of the IRS and some states to recommend—or, in a few cases, require—the use of driver’s license numbers as form of authentication on electronically filed personal tax returns has made them a higher-value target for hackers and other criminals.
Rules proposed for accounting method changes to reflect FASB revenue recognition standards
The IRS is asking for comments on proposed procedures for requesting consent to make accounting method changes to reflect FASB’s new revenue recognition standards.
IRS issues 2017 car and truck depreciation limits
The IRS released the inflation adjustments to the depreciation limits for cars and trucks used for business purposes in 2017.
Amazon wins multimillion dollar transfer-pricing dispute with IRS
The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.
Disbarred tax preparer not subject to IRS jurisdiction
The IRS Office of Professional Responsibility has no authority or jurisdiction over a disbarred attorney/tax preparer or his tax preparation practice and cannot regulate his provision of tax advice a federal district court in Nevada has held.
Taxpayers affected by winter storm get more time to file business return extensions
The IRS announced that it would grant “eligible taxpayers” who are affected by this week’s winter storm on the East Coast extra time to file their requests for filing extensions.
IRS takes down student financial aid data retrieval tool
The IRS announced that has taken down its tool for retrieving tax return data used to complete the Free Application for Federal Student Aid.
Proposed PPACA replacement bills contain many tax changes
The draft proposals to repeal the Affordable Care Act released by House Republicans would make many tax changes if enacted. Here’s a look at their impact on the tax code.
State issues with the new federal partnership audits
The AICPA leads effort to promote state-level uniformity.
Medical practice owner is held liable for employment taxes
A self-imposed loan restriction to pay salaries does not encumber funds owed to the government.
Line items
FBARs get automatic extensions…Eligibility rule waiver extended for tangible property regs. automatic method changes…Standard mileage rates for 2017
S corporation’s sole owner had unreported income but not constructive dividend
The Tax Court cites a lack of earnings and profits.
Like-kind exchange between related parties denied nonrecognition treatment
The Tax Court rejects a taxpayer’s argument for an exception under Sec. 1031(f)(2)(C) of no principal purpose of tax avoidance.
Congress authorizes new small business HRAs
Popular employer arrangements to reimburse medical expenses had been penalized by the Affordable Care Act.
Final rules on Sec. 367 transfers of intangibles apply retroactively
The treatment of foreign goodwill or going concern value is clarified.
New PATH for depreciation
Changes to 15-year and bonus depreciation rules and Sec. 179 expensing may deliver tax savings to business clients.
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From The Tax Adviser
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AI risks to the Sec. 7525 practitioner privilege
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Navigating the QSBS rules in pass-through structures
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Sec. 338(h)(10) elections in business acquisitions
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