The IRS finalized proposed regulations to update the rules that apply to U.S. taxpayers that fail to file gain recognition agreements (GRAs) when they transfer certain property to foreign corporations in nonrecognition transactions (T.D. 9704). The rules change the standards under which transferors are required to recognize gain on the
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Tax
G-20 leaders commit to automatic exchange of tax information
“Profits should be taxed where economic activities deriving the profits are performed and where value is created”—so said the leaders of the G-20 major economies as they endorsed the Organisation for Economic Co-operation and Development’s (OECD’s) global standard for automatic exchange of tax information at the G-20 summit in Brisbane,
IRS fills in details of one-a-year IRA rollover rule
The IRS clarified how the recently announced change in how it interprets the statutory one-rollover-per-year rule for individual retirement arrangements (IRAs) will affect 2014 rollovers and how the rules will apply starting in 2015 (Announcement 2014-32). Sec. 408(d)(3)(A)(i) permits a tax-free rollover of funds in a taxpayer’s IRA as long
Regulations finalize rules on all-cash D reorganizations
On Monday, the IRS finalized temporary regulations regarding the determination of the basis of stock or securities in all-cash D reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction (T.D. 9702). The regulations clarify that in these transactions, only a shareholder that
Final rules determine how E&P is treated in corporate reorganizations
New rules under Sec. 381 will change which corporation succeeds to the tax attributes, including the earnings and profits (E&P), of the transferor or distributor corporation in certain acquisitions. T.D. 9700, issued on Friday by the IRS, also finalizes other related proposed regulations under Sec. 312 clarifying that, in certain
Filing season complications loom, IRS commissioner tells AICPA
The 2015 tax filing season “will be one of the most complicated filing seasons we’ve ever had,” IRS Commissioner John Koskinen said in a keynote address Tuesday to hundreds of attendees at the AICPA National Tax Conference in Washington. He also held out hope of penalty relief for taxpayers affected
Form 990: Late filing penalty abatement
Several types of relief may be available to not-for-profit organizations that incur penalties for violating complex filing requirements.
Whistleblower awards widened
Final rules expand the definitions of collected proceeds and eligible individuals, and specify the criteria for award amounts. Comprehensive final regulations issued in August provide rules for whistleblower awards under Secs. 7623(a) and (b), as well as rules governing the disclosure of return information under Sec. 6103(h) to pursue these
Research and experimentation expenditures clarified
With enhanced definitions and numerous additional examples, final regulations issued in July (T.D. 9680) clarify research and experimentation (R&E) expenditures under Sec. 174 that may be deducted currently or capitalized and amortized. Under the final regulations, the ultimate success, failure, sale, or use of a product is not relevant to a determination
New IRS appeals process launched
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
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
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