While the comprehensive corporate tax reform desired by the business community remains highly elusive, businesses did receive a number of concessions via the American Taxpayer Relief Act of 2012 (ATRA), P.L. 112-240, which was signed into law Jan. 2, 2013. The act extends through 2013 an assortment of expired or
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Tax
Parent corporation’s options treated as positions held by subsidiaries
In a Field Attorney Advice (FAA) memo, the IRS Office of Chief Counsel (OCC) advised that a parent corporation’s S&P 500 options held to hedge against price fluctuations of the equity portfolio held by four related subsidiaries should be treated as positions held by the subsidiaries. Consequently, the holding period
The rules on providing client records
Suppose a CPA who prepared a client’s tax returns receives a request from the client that the CPA transfer all of the client’s tax records to a new firm. The client includes the appropriate Sec. 7216 consent to disclose authorization to transfer the records. What are the CPA’s responsibilities and
Final regs. clarify who is subject to 50% limit on meal and entertainment expenses
On Wednesday, the IRS issued final regulations clarifying which party is subject to the 50% limit on deductible meal and entertainment expenses under Sec. 274(n) (T.D. 9625). The final rules adopt proposed regulations issued in July 2012 (REG-101812-07) without substantive change. As the IRS emphasized in the preamble to the
Comments requested on proposed net investment income tax form
On Monday, the IRS published a notice and request for comments from taxpayers on a new dual-purpose form that will be used by individuals (using Form 1040, U.S. Individual Income Tax Return) and trusts and estates (using Form 1041, U.S. Income Tax Return for Estates and Trusts) to compute the
New method for determining who gets Sec. 199 deduction under contract manufacturing arrangements
The IRS issued new guidance to examiners in its Large Business & International (LB&I) Division regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement (LB&I-04-0713-006). The new directive replaces earlier guidance (LB&I-4-0112-001) issued last year, which had
Rules for deferral of income from gift card sales clarified
The IRS issued guidance clarifying that taxpayers that sell gift cards can defer recognizing income from the sale of gift cards redeemable by an unrelated third party until the year after the payment is received (Rev. Proc. 2013-29, clarifying and modifying Rev. Proc. 2011-18). With the rapid growth in the
Identity theft protection process at IRS needs improvements, TIGTA says
Identity theft was the number one type of consumer complaint in 2011, according to the Federal Trade Commission, and some practitioners have asked if tax-related identity theft has become an epidemic. In light of the growing problem, the Treasury Inspector General for Tax Administration (TIGTA) recently audited the IRS’s Taxpayer
July 22 IRS furlough day canceled
The IRS canceled its scheduled furlough day for Monday, July 22, acting IRS chief Danny Werfel announced on Tuesday. Instead of closing and sending IRS workers home for a day of unpaid leave, “[t]he IRS will be open for taxpayers that day as scheduled,” he said in a message to
FATCA deadlines are postponed for six months
On Friday, the IRS said it was delaying for six months some of the deadlines for implementing the Foreign Account Tax Compliance Act (FATCA) originally set out in the final regulations issued in April in T.D. 9610 (Notice 2013-43). The regulations, which provide rules on information reporting by foreign financial
IRS provides details about postponed employer health care penalty and information reporting
On Tuesday, the IRS made official the postponement of the large-employer health care penalty and certain information reporting rules that had been informally announced July 2 on a Treasury Department blog. Notice 2013-45 postpones the information reporting rules under Secs. 6055 and 6056 and the Sec. 4980H shared responsibility penalty
Professional poker player goes bust in Tax Court
A professional poker player who was also a civil and geotechnical engineer and a laundromat owner lost in Tax Court on Monday (Hom, T.C. Memo. 2013-163). The court held that John Hom received unreported wages from his wholly owned C corporation, could not deduct unsubstantiated gambling losses or travel expenses,
Final rules on acceleration of COD income deferral are issued
The IRS on Tuesday issued final regulations on the rules to accelerate cancellation of debt (COD) income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010 (T.D. 9622 and T.D. 9623). An
Treasury postpones employer health care penalty, information reporting for one year
Large employers that fail to provide minimum health coverage for employees will not be subject to the shared-responsibility penalty until 2015 after Treasury announced on Tuesday that it would delay certain provisions of 2010’s health care legislation. In a Treasury blog post titled, “Continuing to Implement the ACA in a Careful,
IRS offers new method for home office deductions
Working at home has come a long way from the days when employers were most concerned that they would not get their money’s worth if they allowed employees to do so. Instant communication, improved internet access, and more stable virtual network connections have changed the equation for employers, who now
IRS finds widespread noncompliance by colleges and universities
The IRS published its final report concerning its Colleges and Universities Compliance Project, finding compliance issues related to unrelated business taxable income (UBTI) and compensation practices. The IRS conducted the study to find out why colleges and universities had so much unrelated business activity but owed so little tax and
PFP Q&A: Planning for change
With the Baby Boomer generation hitting retirement age, personal financial planning has become an increasingly important service for many accounting firms. But practitioners are dealing with plenty of changes, including the implementation of new tax laws and the landmark rollout of new standards. The JofA assembled a team of industry
Salary was partially reasonable
Relying on standards set by the Ninth Circuit, the Tax Court found that a sole shareholder’s compensation from a wholly owned corporation for the year in question was partially deductible as reasonable compensation. The deductible compensation included catch-up payments for prior years’ services. Arthur Astor was the president and CFO
Basis reporting for debt instruments and options is phased in
In final regulations (T.D. 9616), the IRS is phasing in basis reporting requirements under Sec. 6045(g) for debt instruments and options. The IRS took the action in response to comments about the complexity of complying with these rules and to give brokers ample time to develop and implement reporting systems.
Voluntary Classification Settlement Program
Determining proper classification of workers, either as independent contractors or employees, can be a subjective challenge for employers. The determination of whether a worker is an employee or an independent contractor is based on the facts and circumstances surrounding the individual’s work for the employer. Generally, the more the employer
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