Tokyo and Hong Kong have the highest allowable housing costs for 2013 for purposes of the foreign housing exclusion under Sec. 911(c). The limitation for Tokyo is $320.82 per day, or $117,100 for the entire year. For Hong Kong, it is $313.15 a day, or $114,300 for the year. The
Advertisement
TOPICS
Tax
HSA inflation adjustments issued for 2014
On Thursday, the IRS issued the inflation-adjusted figures for the annual contribution limitation for health savings accounts (HSAs) and the minimum deductible amounts and maximum out-of-pocket expense amounts for high-deductible health plans for calendar year 2014 (Rev. Proc. 2013-25). Under Sec. 223, individuals who participate in a health plan with
Proposed rules address minimum value of health coverage for premium tax credits
The IRS issued proposed regulations for determining whether an eligible employer-sponsored health plan provides minimum value for purposes of the Sec. 36B health insurance premium tax credit (REG-125398-12). Individuals do not receive the credit if they are eligible for affordable coverage under an eligible employer-sponsored plan that provides minimum value.
Dow SLIPs in court
The U.S. District Court for the Middle District of Louisiana disallowed deductions generated by two Special Limited Investment Partnerships (SLIPs) transactions because the transactions lacked economic substance and did not have a nontax business purpose. In addition, the court found that the two partnerships at the heart of the transactions
LLC’s use of deferral method for advance payments upheld
The Tax Court found that an IRS Criminal Investigations Division agent and his wife, a school manager, could use the deferral method to report certain advance payments relating to their private school LLC-partnership. Further, the court upheld the treatment of payments that the couple made to the LLC-partnership as capital
TIGTA: Noncash charitable contribution claims still often erroneous
The Treasury Inspector General for Tax Administration (TIGTA) estimated that more than 273,000 taxpayers claimed $3.8 billion in potentially erroneous noncash charitable contribution deductions in tax year 2010. The audit report’s findings (Rep’t No. 2013-40-009) echoed TIGTA’s previous examinations of noncompliance in 2007 and 2009. In the latest review, released
Conservation easement tax donation update
The deductibility of a charitable donation for a conservation easement or restriction on a real property interest is provided for under Sec. 170(h). Even with almost 13 pages of regulations (Regs. Sec. 1.170A-14), this provision is not straightforward, as evidenced by the number of taxpayers challenged by the IRS. Careful
Qualified small business stock
For taxpayers other than corporations, Sec. 1202 excludes from gross income at least 50% of the gain recognized on the sale or exchange of qualified small business stock (QSBS) that is held more than five years. For qualifying stock acquired after Feb. 17, 2009, and on or before Sept. 27,
Most whistleblower awards still under pre-2006 law
In its latest annual report to Congress on the whistleblower program Feb. 13, the IRS said it received hundreds of submissions during the 2012 fiscal year (FY) that appeared to meet the higher underpayment threshold for enhanced awards, enacted in 2006. Nearly all of the awards paid during the fiscal
Long-awaited final regs. issued on noncompensatory partnership options
The IRS issued regulations (T.D. 9612) finalizing proposed regulations (REG-103580-02), which were issued in January 2003, on the treatment of certain call options, warrants, convertible debt, and convertible equity that are not issued in connection with the performance of services, i.e., noncompensatory partnership options. The final regulations apply to noncompensatory
A conversation about tax reform
Sponsored by Drake Software As Congress took steps earlier this year to enact the first major tax reform since 1986, the JofA turned to three leaders in tax policy for their thoughts on the directions, goals, and prospects for reform. Two of them participated as tax counsel staff to congressional
When is a casualty “sudden, unexpected, or unusual”?
The Second Circuit’s recent remand of Alphonso, No. 11-2364-ag (2d Cir. 2/6/13), rev’g 136 T.C. 247 (2011) (see “Tax Matters: Co-op Lessee Has Property Interest in Collapsed Wall,” on page 73), allows the Tax Court to consider perhaps the most controversial aspect of casualty loss deductions—the meaning of “sudden, unexpected,
AICPA makes tax reform recommendations to Ways and Means Committee working groups
In response to concerns that “[t]he proliferation of new income tax provisions since the 1986 tax reform effort has led to complex compliance hurdles for taxpayers, administrative complexity and enforcement challenges for the Internal Revenue Service,” the AICPA submitted recommendations for tax reform to five of the 11 working groups
Widow avoids jail time and probation in sentencing for offshore account tax evasion
Wealthy Palm Beach resident Mary Estelle Curran was sentenced to one year of probation in federal district court Thursday, following her guilty plea to charges of tax evasion. However, Judge Kenneth Ryskamp almost immediately revoked that sentence, reportedly telling the prosecutors that he thought the prosecution had been unnecessary and
IRS decides to shut down completely on furlough dates
Acting IRS Commissioner Steve Miller announced that the IRS will close “all public-facing operations,” including toll-free operations and Taxpayer Assistance Centers, on May 24, June 14, July 5, July 22, and August 30, with another two days of closings possible in August or September, in response to the budget cuts
Basis reporting for debt instruments and options is phased-in
In final regulations implementing the basis reporting requirements under Sec. 6045(g) that apply to debt instruments and options, the IRS, in response to comments about the complexity of complying with these rules, is implementing the reporting requirements for debt instruments and transfer reporting in phases, to give brokers ample time
Boston-area residents get more time to file returns and pay tax
In response to Monday’s bombings at the Boston Marathon, the IRS announced late Tuesday that it is extending the time for filing certain individual tax returns that were due April 15 and paying any tax due until July 15. “Our hearts go out to the people affected by this tragic
Witnesses tell Senate Finance Committee ways to improve tax system
Witnesses gave the Senate Finance Committee a variety of suggestions on how to fight tax identity theft and fraud, reform the tax system, and fund the IRS during a hearing on Tuesday. The committee heard from witnesses representing the IRS, the Taxpayer Advocate Service, the Social Security Administration (SSA), and
A look at the estate tax provisions in the president’s FY 2014 budget proposal
President Barack Obama’s recently released FY 2014 proposed budget contains a number of estate, gift, and generation-skipping transfer (GST) tax proposals. The most far-reaching would permanently return the estate, gift, and GST tax regimes to the 2009 rules, starting in 2018. This would mean a 45% top tax rate and
Significant decline in IRS staff leads to fewer audits
The Transactional Records Access Clearinghouse (TRAC), reports that the IRS plans to expend 18% fewer staff hours auditing large businesses with assets of more than $10 million in fiscal year 2013 (which ends Sept. 30) than it did in FY 2011. These lower numbers do not take into account the
Features
FROM THIS MONTH'S ISSUE
AI risks CPAs should know
Are you ready for the AI revolution in accounting? This JofA Technology Q&A article explores the top risks CPAs face—from hallucinations to deepfakes—and ways to mitigate them.
From The Tax Adviser
January 31, 2026
Trust distributions in kind and the Sec. 643(e)(3) election
January 31, 2026
Effects of the OBBBA on higher education
December 31, 2025
