Planning to lessen estate, gift, and generation-skipping transfer taxes increasingly requires considering clients’ foreign connections.
Advertisement
TOPICS
Tax
Court rejects ‘in-substance’ small-partnership argument
A partnership with a passthrough partner owning a 0.02% partnership interest is ineligible for the small partnership exception under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA).
Notice clarifies provider list rules for charitable hospital financial assistance policies
The IRS issued a notice that clarifies how a charitable hospital organization may comply with the requirement to include a provider list in its financial assistance policy.
Congress makes changes to tax code in trade preferences act
The bill modifies the Sec. 35 health coverage tax credit and the Sec. 24 child tax credit, requires payee statements for the education credits, changes the time for payment of certain corporate estimated taxes, and increases information return and payee statement penalties.
Supreme Court upholds health insurance subsidies in federal exchanges
In a 6–3 decision, the U.S. Supreme Court held that Sec. 36B premium tax credits are available to taxpayers who purchase health insurance on exchanges run by the federal government under the Patient Protection and Affordable Care Act.
Proposed rules for ABLE accounts for the disabled are issued
Proposed regulations under Sec. 529A were issued providing guidance on ABLE accounts, special tax-favored accounts designed to help disabled individuals and their families save for and pay disability related expenses.
IRS issues guidance for multiemployer plans to apply for benefit suspension approval
The IRS released regulations and a revenue procedure containing guidance for sponsors of multiemployer plans that have insufficient funds to pay benefits, to apply for approval of a suspension of benefits.
IRS issues final portability rules for estate tax exemptions
The IRS issued final regulations on the portability of deceased spouses’ unused estate tax exemption amounts, which allows surviving spouses to use unused amounts of exemption from the estate tax in addition to their own exemptions.
Tax industry and IRS team up to fight identity theft refund fraud
the IRS announced that it agreed to partner with a number of tax preparation firms, state tax administrators, and other interested parties to fight identity theft refund fraud.
IRS: Corporations cannot circumvent gain on appreciated property using partnerships
The IRS issued temporary regulations designed to prevent corporations from avoiding gain on the distribution of appreciated property through the use of partnerships.
Bright-line test determines substantial business activities under inversion rules
The bright-line test introduced in 2012 amended the existing rules that applied a facts-and-circumstances test.
Expanded IRS online services put taxpayer information at risk, Senate committee told
IRS Commissioner John Koskinen revealed more details about the theft of 100,000 taxpayers’ data through the Get Transcript system.
New accounting method change procedures give more time to file Form 3115
The IRS updated its recently amended procedures for requesting approval for accounting method changes.
Retail buildings placed in service before being open for business
Building materials and supplies stores were ready and available to perform their assigned function.
No Sec. 199 deduction for these activities
The IRS Large Business & International (LB&I) Division issued guidance to its employees listing activities performed “at the retail level” that it said do not produce property that is “manufactured, produced, grown, or extracted,” as defined by Regs. Sec. 1.199-3(e).
Helping S corporations avoid unreasonable compensation audits
The IRS aggressively audits S corporations to make sure they do not disguise compensation as distributions to shareholders. Here’s what tax preparers need to know to avoid red flags in S corporation returns.
Final regulations amend broker basis reporting requirements
Basis calculation elections, OID on tax-exempt obligations, and Sec. 1256 option transfers to other brokers are among areas addressed.
Tax engagement letters
Use of this important practice tool can minimize professional liability risk, reduce confusion, improve collections, and ensure clients have a good understanding of the practitioner’s role.
Taxes and the rescission doctrine
This doctrine allows taxpayers to “unwind” a tax transaction.
U.S. abode binds Russian-employed taxpayer
A taxpayer’s strong ties to the United States led to denial of the foreign earned income exclusion despite his spending half his time living and working overseas.
Features
ALSO FEATURED
How to protect nonprofits from hidden fraud risks
CPAs can help not-for-profits spot the red flags of common schemes, so they can take steps to tighten controls and reduce exposure.
From The Tax Adviser
March 31, 2026
Current developments in taxation of individuals: Part 1
March 31, 2026
Current Developments in Taxation of Individuals: Part 1
March 6, 2026
