In two announcements on Friday, the IRS unveiled a number of significant changes to its plan to require certain business taxpayers to report uncertain tax positions on their tax returns (Announcements 2010-75 and 2010-76). The changes come in response to numerous comments received on the proposal and on the draft
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Small Business Stimulus Passes Congress
The House on Thursday passed the Small Business Jobs Act of 2010 (HR 5297) by a vote of 237–187, and sent it to the President, who is expected to sign the bill into law. The bill, which passed the Senate last week, expands loan programs through the Small Business Administration
Senate Passes Small Business Tax Relief
The Senate on Thursday passed the Creating Small Business Jobs Act of 2010 (part of the Small Business Jobs and Credit Act, HR 5297) by a vote of 61–38, and sent it back to the House of Representatives. The bill as passed by the Senate differs from the version the
IRS Says It Won’t Give Advance Guidance on Transactions Under Codified Economic Substance Doctrine
The IRS issued its first guidance on the newly codified economic substance doctrine on Monday (Notice 2010-62). In general, the IRS says it will enforce the two-prong test mandated in the Code and will not issue guidance on whether specific transactions pass muster. The economic substance doctrine was originally created
IRS Releases Proposed Regs on Series LLCs
On Monday, the IRS released proposed regulations on the tax treatment of series limited liability companies (LLCs) and cell companies, proposing to treat the individual series or cells as separate entities for tax purposes (REG-119921-09). Eight states and Puerto Rico have enacted series LLC statutes that allow an LLC to
IASB Proposes Amendment to Aspect of Deferred Tax Accounting
The International Accounting Standards Board (IASB) on Friday published for public comment an exposure draft, Deferred Tax: Recovery of Underlying Assets, that would amend one aspect of IAS 12, Income Taxes. The IASB said it is setting an exposure period of 60 days—shorter than its normal 120 days—because the amendments
IRS Issues Proposed Regs Requiring Disclosure of Uncertain Tax Positions
The IRS issued proposed regulations (REG-119046-10) that would require certain business taxpayers to report uncertain tax positions on their tax returns. The regulations are the latest step in an initiative the IRS launched in January with the release of Announcement 2010-9. In April, the IRS released a draft Schedule UTP,
Draft Form for Small Business Health Insurance Credit Released
The IRS on Tuesday issued a draft form for businesses to use in figuring and claiming the new small business health insurance credit, starting this year. Draft Form 8941, Credit for Small Employer Health Insurance Premiums, leads taxpayers through the steps of determining the number of full-time equivalent employees, average
Treasury Announces Low-Cost Financial Account Program for Taxpayers
In a move that may cut down on the use of refund anticipation loans (RALs), the Treasury Department announced on Thursday the launch of a pilot program to provide taxpayers with access to low-cost financial accounts. This is the second action in the past month the Treasury Department has taken
Featured Online Content for September 2010
FEATURED VIDEO Tax Software Survey Analysis In this video, JofA Senior Editor Alexandra DeFelice discusses what more than 12,000 CPAs had to say about their tax preparation software and provides analysis of some tax software trends to watch. Also on journalofaccountancy.com, find more information about each tax preparation software vendor,
Comments Requested on Expanded Payment Information Reporting
The IRS requested comments on 2012-effective amendments to IRC § 6041 expanding requirements to report on Form 1099 business payments totaling $600 or more to any person in a calendar year. The amendments were made by the Patient Protection and Affordable Care Act of 2010 (PL 111-148). They provide that,
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PENSIONS GET FUNDING RELIEF President Barack Obama signed HR 3962, the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010, on June 25. The act allows single-employer plans to elect to amortize over a longer period pension shortfalls caused by losses in asset value they
Two-Year Limit on Equitable Relief Petitions Upheld
The Seventh Circuit Court of Appeals reversed the Tax Court and upheld IRS regulations restricting to two years the period in which taxpayers can petition under IRC § 6015(f) for equitable innocent spouse relief from joint and several liability. Cathy Lantz was married to a dentist convicted of Medicare fraud.
Determining Ownership Changes When Stock Prices Fluctuate
In an effort to limit loss trafficking, Congress enacted IRC § 382 to limit the use of corporate net operating losses (NOLs) following an ownership change, which is defined generally as a greater than 50% change in stock ownership among certain 5% shareholders over a three-year period. In the event
2010 Tax Software Survey
The Journal of Accountancy and The Tax Adviser conducted a survey of AICPA members who prepared 2009 tax returns for a fee to determine which tax preparation software products were the most popular, what aspects of those products preparers liked, and what they disliked. Of the 17 products identified for
Gary Iskowitz, CPA
I am fortunate to have a successful practice comprised of a partner and 12 staff members; we work with high-income individuals in the Los Angeles area. I am also fortunate to have had both local and national television exposure. And I owe these things to an unlikely source—the Internal Revenue
New Life for Charitable Lids
One common estate planning technique the IRS has opposed or blocked for years is “charitable lid planning.” This technique relies on “defined value” and “value adjustment” clauses or similar provisions in wills, deeds or other transfer documents to cap the transfer taxes on estates, gifts or generation-skipping trusts at some
Best Practices for Exempt Organizations and Form 990
Tax-exempt organizations required to file federal Form 990, Return of Organization Exempt From Income Tax, which was expanded and revised beginning in 2008 tax years, now have some experience with the new requirements. They may have experienced much anxiety as they and their CPAs learned that the new Form 990
Son Liable for Father’s Unpaid Taxes
The Tax Court affirmed an IRS determination that a son is liable for his father’s unpaid taxes as the transferee of his father’s Florida condominium. Florida’s Uniform Fraudulent Transfer Act (FUFTA) did not protect the son from the liability. When his mother’s health declined in 1989, Scott Rubenstein moved from
Currency Option Not a Contract in “Major/Minor” Shelter
The Tax Court held that a foreign currency call option is not a foreign currency contract under the plain language of the IRC § 1256 contract mark-to-market rules. Thus an unrealized loss existing on the date that a foreign currency option was transferred to a charity was disallowed. Section 1256
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