Cases lacking documentation or adherence to procedural requirements or that have new taxpayer information will be returned to Examination. In September, the IRS Office of Appeals began a policy of hearing only cases that are fully developed; hearing officers will not do their own investigations and will send any new
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Tax
Guidance issued on markdown allowances and margin protection payments
Final rules clarify retailers’ treatment of vendor discounts in inventory valuation. Final regulations restate and clarify retailers’ computation of ending inventory value, including the application of common vendor discounts. The amendments to Regs. Sec. 1.471-8 are intended to render that section’s provisions in plainer language and provide rules for how
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
Aircraft rental is passive activity
Failure to properly document material participation prompts a Tax Court ruling that an aircraft rental activity is passive. The Tax Court held that losses from an aircraft rental activity were passive and could not be used to offset income from other business sources. The ruling was based on the taxpayer’s
Jeopardy and termination assessment cases
In some circumstances, the IRS may resort to a series of procedures known as jeopardy or termination assessment and collection. If the IRS believes that the collection of an unassessed liability is in jeopardy, it may take steps to begin collection proceedings without following the normal assessment and collection procedures
Father was custodial parent for dependency exemption and earned income credit
The IRS misapplied the Sec. 152(e) waiver requirements, the Tax Court holds. Even though a divorce instrument awarded custody of a child to her mother, the child’s father could claim the child for a dependency exemption and earned income tax credit because he was the custodial parent, the Tax Court
Proposed rules would change partners’ treatment of unrealized receivables and inventory items
On Friday, the IRS issued proposed regulations under Sec. 751 that would amend the rules governing how a partner measures its interest in a partnership’s unrealized receivables and inventory items and the tax consequences of a distribution to a partner reducing that interest (REG-151416-06). Sec. 751 was enacted to prevent
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
Defined contribution plans can offer deferred annuities to older participants
Under guidance released on Friday, qualified defined contribution plans will be allowed to provide lifetime income to plan participants by offering funds including deferred annuities among their assets, even if some of the funds are available only to older plan participants (Notice 2014-66). In the notice, the IRS explained how
Social Security Administration announces 2015 wage base
On Wednesday, the Social Security Administration (SSA) announced that the wage base above which taxes for old age, survivors, and disability insurance (OASDI) are not due will increase from $117,000 to $118,500 in 2015. The new rate means employees will pay a maximum of $7,347 of OASDI in 2015, with
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
Proposed regs. would eliminate 36-month testing period from COD reporting requirements
Because the IRS believes that requiring the filing of Form 1099-C, Cancellation of Debt, at the expiration of a 36-month nonpayment of debt testing period “creates confusion for taxpayers” and does not increase tax compliance, the Service released proposed regulations to eliminate the rule (REG-136676-13). Under Sec. 6050P and its
Changes made to IRS streamlined offshore compliance procedures
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed
Certain FATCA deadlines are postponed
The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee
Notice defines terms for economic substance doctrine
On Thursday, the IRS provided guidance defining “transaction” for purposes of applying the Sec. 7701(o) economic substance doctrine and “similar rule of law” for purposes of the Sec. 6662(b)(6) accuracy-related penalty (Notice 2014-58). The economic substance doctrine is a common law judicial doctrine that disallows tax benefits of a transaction
AICPA asks for raise in repair regulations’ de minimis safe harbor threshold
Jeffery Porter, CPA, chair of the AICPA’s Tax Executive Committee, wrote to Andrew Keyso, IRS associate chief counsel, on Wednesday, raising the AICPA’s concerns about the low amount of the de minimis safe harbor threshold in the tangible property regulations (T.D. 9636) that were issued in September 2013, and about
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.
The tip of the iceberg: Professional liability claims and international taxation
International tax issues can present significant challenges for a CPA firm. Even the smallest client may provide goods or services outside the United States or use a foreign supplier, sometimes without the CPA even realizing it.
Sec. 121 gain exclusion does not offset suspended passive losses
Qualifying taxpayers who convert a principal residence to rental property and sell it can exclude gain under Sec. 121 without offsetting any passive losses carried forward. The IRS concluded in a Chief Counsel Advice memo (CCA) that excluded gain from the sale of a former principal residence that was converted
Qualified lessee construction allowances
Under Sec. 110, certain businesses that are tenants of a retail space may exclude from gross income amounts received from the lessor of the space to construct or improve real property used in the taxpayer’s trade or business. This safe harbor applies where the lease is for 15 years or
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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
