The IRS received an overwhelming flood of comments in response to proposed regulations it issued last November on the rules governing the political activities of Sec. 501(c)(4) social welfare organizations. As a result, the IRS announced that it will repropose the regulations, after taking the comments into account, and will
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Tax
AICPA has “deep concerns” about IRS voluntary certification of return preparers
Following the defeat in federal court of the IRS’s tax return preparer regulation program, IRS Commissioner John Koskinen has commented that the IRS should consider a voluntary certification program for tax return preparers. On Wednesday, the AICPA sent the commissioner a letter, expressing its “deep concerns” about such a program.
Tax lawyer: Code reform stymied by dysfunctional Congress
Passage of major tax reform legislation appears unlikely soon, partly because of partisan gridlock in Congress as bad as any in the past century and a half, a noted tax lawyer told the AICPA spring Council on Tuesday in Scottsdale, Ariz. “Now, the members aren’t even acting in their own
Notice clarifies midyear amendment of certain retirement plans post-Windsor
The IRS clarified that a qualified retirement plan will continue to be a qualified 401(k) or 401(m) safe-harbor plan if it adopts a midyear amendment to its plan to comply with the rules in Notice 2014-19 requiring qualified plans to conform to the Windsor decision (Notice 2014-37). A safe-harbor 401(k)
Commissioner calls for greater IRS funding
The IRS needs more money to effectively do its job, especially with its added responsibilities under the Patient Protection and Affordable Care Act. That was the message IRS Commissioner John Koskinen delivered to attendees at the American Bar Association Tax Section’s spring meeting in Washington on Friday. It was standing
Final rules govern tax treatment of distributions to pay accident or health insurance premiums
On Friday, the IRS finalized regulations that provide that distributions from qualified retirement plans to pay accident or health insurance premiums are taxable unless a statutory exclusion applies (T.D. 9665). However, arrangements where amounts are used to pay premiums for disability insurance to replace retirement plan contributions in the event
Businesses lagging in preparation for new health care laws
Many U.S. employers are lacking in preparation for—and awareness of—new health care laws, according to a survey. More than one-third (36%) of more than 800 corporate decision-makers said they are not very familiar with the requirements of the Patient Protection and Affordable Care Act, P.L. 111-148, according to a survey
Final rules on fiduciary fees are issued
The IRS issued final regulations on the controversial question of which costs incurred by trust and estates are subject to the 2% floor on miscellaneous deductions under Sec. 67(a) (T.D. 9664). The regulations will apply to tax years beginning on or after May 9, 2014. The final regulations retain from
Accounting method change procedures for sales-based royalties and vendor allowances are announced
Taxpayers who are adopting the rules for sales-based royalties and vendor allowances under Sec. 263A and Sec. 471 provided in T.D. 9652 were given new procedures for obtaining automatic consent to accounting method changes to conform to those rules (which apply to tax years ending on or after Jan. 13,
Proposed rules would amend definition of acquiring corporation in corporate reorganizations
On Tuesday, the IRS issued proposed regulations under Sec. 381 that in certain acquisitions would change which corporation succeeds to the tax attributes, including the earnings and profits (E&P), of the transferor or distributor corporation (REG-131239-13). In earlier, related proposed regulations under Sec. 312, the IRS clarified that, in certain
Tax owed on full sale price where taxpayer won’t provide cost basis information
The Eleventh Circuit Court of Appeals upheld a deficiency notice of more than $5 million against a taxpayer who reported adjusted gross income of $22,921 and taxable income of $13,221 on his late-filed 2006 return (Hoang, No. 13-14398 (11th Cir. 5/2/14), aff’g T.C. Memo. 2013-127). Diep Hoang’s 2006 tax return
IRS announces two-year FATCA enforcement transition period
Foreign financial institutions that make a good-faith effort to comply with the requirements of the Foreign Account Tax Compliance Act (FATCA) will benefit from lighter enforcement during 2014 and 2015, the IRS announced on Friday (Notice 2014-33). The IRS is treating those years as a “transition period” for the implementation
Accounting across borders
CPA firms are finding international services a booming business, based on responses to a recent AICPA Private Companies Practice Section (PCPS) survey. The survey examines practitioners’ interest in expanding to new markets and growing an international clientele, as well as firms’ top international challenges and needs.
New rules for innocent spouse equitable relief
A new, more comprehensive revenue procedure may spell equitable relief for many more taxpayers.
Conflicts of interest and client consent
Section 10.29 of Treasury Circular 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R. Part 10), generally prohibits a practitioner from representing a client before the IRS if the representation involves a conflict of interest. Under Section 10.29(a), a conflict of interest exists if: (1) The representation of
QSub election does not create an item of income
The Third Circuit affirmed the Tax Court’s opinion that an S corporation’s election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary (QSub) did not create an item of income or tax-exempt income under Sec. 1366(a)(1)(A). It also determined that an increase in stock bases and declared
IRS provides simplified employer health care coverage reporting
The IRS released final regulations to implement simplified reporting requirements of employers to report health care coverage information under Secs. 6055 and 6056 starting in 2015 (T.D. 9660 and T.D. 9661). Sec. 6055 requires providers of minimum essential coverage and providers of coverage through an employer’s group health plan to
Final FATCA rules are issued
The IRS released regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to
The de minimis safe harbor under the repair regulations
Among the more welcome changes adopted in the final tangible property repair regulations (T.D. 9636) is the de minimis rule related to the acquisition or production of property (Regs. Sec. 1.263(a)-1(f)). This rule provides for a safe harbor applied at the invoice or item level, based on the policies used
Final rules on substantial risk of forfeiture are released
The IRS finalized regulations that clarify when a substantial risk of forfeiture exists on the transfer of stock to an employee that is treated as compensation under Sec. 83. If a substantial risk of forfeiture exists, the employee does not have to recognize the income at the time of the
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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
