The Tax Court held that Regs. Sec. 1.482-7(d)(2), requiring entities to share stock-based compensation costs under qualified cost-sharing agreements, failed to meet the reasoned decision-making standard and was invalid.
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Tax
Regulations provide guidance on proper place to file refund claims
The new rules generally require taxpayers filing claims for refund or credit to file their claim with the IRS service center at which the taxpayers currently would be required to file a tax return for the type of tax to which the claims relate.
Proposed rules define disguised payments for services in partnerships
The IRS will apply a six-factor test to determine whether payments to partners are disguised payments for services under proposed regulations issued today.
Revised Form 3115 issued in draft form
The IRS has posted a draft revised version of Form 3115, Application for Change in Accounting Method, on its website.
Majority of CPAs polled had clients victimized by tax ID theft this year
Many reported it was difficult or very difficult to resolve the issue with the IRS, echoing recent findings by the Taxpayer Advocate Service.
National taxpayer advocate: IRS falling down on the job of helping identity theft victims
Fewer than 10% of callers to the IRS’s phone line for victims of identity theft got through to an IRS assistor during some of the busiest weeks of tax season.
Emerging tax issues cause due-diligence problems
Speaking at an IRS Nationwide Forum in Fort Washington, Md., the deputy director of the IRS Office of Professional Responsibility warned practitioners that they should exercise due diligence when advising clients on emerging tax issues.
Defined benefit plans to be prohibited from replacing annuities with lump-sum payments
The IRS announced that it would amend its regulations under Sec. 401(a)(9) to provide that qualified defined benefit plans cannot replace any joint and survivor, single life, or other annuity currently being paid, with a lump-sum payment or other accelerated distribution.
Documentation is your ally for tax and other services
Practitioners can benefit from documenting their advice in accordance with Circular 230 and the SSTSs.
Managing IRS authorizations
These tools are essential to interact with the IRS on clients’ behalf.
Treatment of CHIP buy-in programs clarified
Taxpayers will be ineligible for premium assistance credits only for periods they are enrolled in a CHIP buy-in program that has been designated as minimum essential coverage.
IRS to limit refunds and credits of foreign withholding payments
Refunds of tax withheld under chapters 3 and 4 will be limited to the amounts actually deposited.
Criminal investigations down in staffing and investigations
The number of new IRS criminal investigations fell markedly in fiscal 2014 from the year before, the Service’s Criminal Investigation Division reported.
Final regs. provide rules for assessment limitation period for undisclosed listed transactions
Coordination with the general limitation period for assessment and the effect of information furnished by a material adviser are among the points addressed.
Tax treatment of employer-provided meals and lodging
The line between exempt fringe benefit and taxable compensation features some surprising twists in this enduring source of tax controversy.
Qualified performance-based compensation rules are finalized
Regs. clarify the per-employee limitation and transition rule for compensation paid before a corporation becomes publicly held.
Financing for college with the Uniform Transfers to Minors Act
Build a fund for higher education with this often overlooked resource.
Filing within 60 days before the assessment period ends
A special rule gives the IRS an extra 60 days to assess tax.
Hold that line
The number of taxpayer phone calls answered by the IRS dropped significantly during the 2015 tax season from the previous year, and call wait times were up, according to an interim report by the Treasury Inspector General for Tax Administration.
Transfer taxes: 5 questions to ask clients with international ties
Planning to lessen estate, gift, and generation-skipping transfer taxes increasingly requires considering clients’ foreign connections.
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