The Tax Court disallowed a taxpayer’s deduction for a conservation easement because the taxpayer’s donated golf course was not a qualified real property interest. The court found that the golf course was not subject to a use restriction in perpetuity since the easement agreement permitted the taxpayer, with the approval
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Tax
IRS extends suspension of examinations of tangible property capitalization issues
On Wednesday, the IRS posted an updated Large Business & Industry (LB&I) Directive for field examinations on the repair vs. capitalization issue that extends the suspension of examinations (LB&I-04-0313-001). The effective date of the tangible property temporary regulations (T.D. 9564) (in amendments published Dec. 17, 2012) has been extended to
Appeals court denies IRS request for stay in return preparer regulation case
The IRS lost another round in its court battle to regulate tax return preparers when the U.S. Court of Appeals for the District of Columbia Circuit denied its motion to stay an injunction halting its return preparer regulation program, pending appeal of a lower court’s decision (Loving, No. 1:12-cv-00385-JEB (D.C.
Identity theft, phishing top IRS’s “Dirty Dozen” tax scams
The IRS issued its “Dirty Dozen” list of tax scams Tuesday, highlighting fraudulent schemes commonly committed by and upon taxpayers. The annual warning, released to coincide with tax filing season, emphasizes the most egregious schemes involving filing false returns or return items, but it also advises yearlong vigilance against practices
“Sovereign citizens” promoter faces up to 164 years in prison
A proponent of the “sovereign citizens” movement and self-proclaimed president of the “Republic for the United States” has been convicted of conspiracy to defraud the United States through a series of seminars in which attendees were taught to pay their federal income taxes by filing fictitious bonds (Turner, No. 1:12cr169-MHT
Taxpayers filing delayed forms get late-payment penalty relief
On Wednesday, the IRS announced that it will waive the penalty normally assessed for late payment of income tax, for taxpayers who have requested an extension of time to file their return and who are filing one of the 31 forms that were delayed until March because of the last-minute
Tax filing resources—Tax year 2012
This is the one-stop shop for all the updates you need to know for this year’s tax filing season. Find resources from the Journal of Accountancy, plus tax return checklists and tax savings tips from the AICPA, categorized by tax topic. INDIVIDUAL TAX All 2012 tax returns can now be
Tax reform prospects good, say veterans of 1986 reform
Developments since the 1986 Tax Reform Act was signed favor a successful outcome for the current reform effort, said two experts who worked for congressional committees producing the earlier legislation. But they also agreed that a tax reform bill probably won’t be enacted until next year. Don Longano and Mel
Regs. issued on asset transfers to foreign corporations
The IRS on Monday issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361. T.D. 9614 contains final regulations that apply to transfers of certain property (including stock and securities) by a domestic corporation to a foreign corporation in certain nonrecognition exchanges and to distributions of stock
Tax Court stops taxpayers from avoiding 40% penalty by conceding on alternative grounds
In a big win for the IRS, the Tax Court refused to grant partial summary judgment to a partner who had conceded his tax shelter case on grounds other than valuation in an attempt to avoid the 40% gross valuation misstatement penalty under Sec. 6662(a) (AHG Investments, LLC, 140 T.C.
Flight attendant cannot claim foreign earned income exclusion for wages earned in international airspace and U.S.
On Wednesday, the Tax Court held that a flight attendant who was a resident of Hong Kong and a U.S. citizen could not claim 100% of her wages were excludable under the Sec. 911 foreign earned income exclusion (Rogers, T.C. Memo. 2013-77). The court also upheld an accuracy-related penalty under
Employers have additional time to claim work opportunity tax credit
On Friday, the IRS announced that it was extending the time employers who want to claim the work opportunity tax credit (WOTC) have to file Form 8850, Pre-Screening Notice and Certification Request for the Work Opportunity Credit (Notice 2013-14). Form 8850 is usually due no later than 28 days after
Sec. 6708 regs. permit material advisers to request extension
On Thursday, the IRS issued proposed regulations under Sec. 6708 governing the penalty for failure of material advisers to provide lists of advisees (i.e., investors) in reportable transactions (as required by Sec. 6112), which applies if the advisers do not supply the lists to the IRS within 20 business days
Sequestration will lead to IRS cuts in services, enforcement, and tax-related payments
Now that sequestration has taken effect, the IRS has announced the following reductions in tax-related payments as a result of the Budget Control Act of 2011, P.L. 112-25. These reductions are effective beginning on March 1, 2013, until either the end of the government’s fiscal year (Sept. 30, 2013) or
All 2012 tax returns can now be filed with IRS
The IRS on Monday announced that it finished updating its processing systems and is now accepting all returns that include the 29 forms that were delayed by the late passage of the American Taxpayer Relief Act of 2012, P.L. 112-240. On Sunday, the IRS began accepting from e-file transmitters returns
The benefits of captive insurance companies
For many years, large corporations in this country have enjoyed many benefits from operating their own captive insurance companies. Most were established to provide coverage where insurance was unavailable or unreasonably priced. These insurance subsidiaries or affiliates were often domiciled offshore, especially in Bermuda or the Cayman Islands. The risk
Rules on use, disclosure of taxpayer information finalized
The IRS issued final regulations under Sec. 7216 that govern the circumstances in which tax return preparers can disclose or use certain limited tax return information (T.D. 9608). The regulations finalize with minor changes rules that were issued in 2010 as temporary and proposed regulations (T.D. 9478 and REG-131028-09). The
The basic framework of cross-border taxation
U.S. citizens are taxable on their worldwide income, with a credit or deduction for taxes paid on foreign income. The United States makes no distinction between earnings from business or investment activities within the United States and those outside its borders. Tax laws governing cross-border transactions are both arcane and
IRS regulation of tax return preparers struck down
A U.S. district court ruled that the IRS’s registered tax return preparer program exceeds its statutory authority and enjoined it from enforcing the regulations (Loving, No. 12-385 (D.D.C. 1/18/13)). In 2011 the IRS issued final regulations (T.D. 9527) making unenrolled return preparers (i.e., return preparers who are not CPAs, attorneys,
Donating and sharing paid time off
Hurricane Sandy highlighted the role of programs that allow employees to donate the value of their unused paid time off (PTO) from work or share it with fellow employees. Following are the main types of programs and their tax treatment. Standard PTO Charitable Donation Programs In this type of program,
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FROM THIS MONTH'S ISSUE
4 ways solo practitioners can stand out
Five years ago, a grieving Angel Zhen started his own CPA firm with no clients and no revenue. Today, he has 300 clients, $600,000 in revenue and 12 weeks of annual vacation. In this JofA article, he shares how he set up his firm and how you could do the same.
From The Tax Adviser
April 30, 2026
Current developments in taxation of individuals: Part 2
April 30, 2026
