The election provided in the American Recovery and Reinvestment Act of 2009 (ARRA) to defer until 2014 and spread over five years cancellation of debt income (CODI) has been touted as an attractive relief option for taxpayers struggling with cash flow problems. However, partnerships and S corporations and their owners
Advertisement
TOPICS
Tax
Health Care Reform Mandates Immediate Changes
The sweeping changes made by the health care reform legislation (the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010) will become effective over the course of several years. However, some employer-related changes are effective as early as the first plan year that
IRS Amends Plan for Uncertain Tax Positions
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 (see Announcement 2010-75 and Announcement 2010-76). The changes, released in September, come in response to numerous comments received on the proposal and on the draft
Navigating Nexus
Nexus can be a hidden danger for a company with a multistate presence. Certain activities might cause nexus for sales and use tax, income tax, franchise tax or other business taxes. One key to successfully navigating these widely varying provisions is for tax professionals to review the statutes and rulings
Preparer Registration Draws Concerns
The IRS moved ahead with its program to register tax return preparers, as aspects of the plan drew concerns and recommendations from a wide range of practitioners and policymakers, including the AICPA. In late September, the IRS issued final regulations (TD 9501 and TD 9503) on preparer tax identification numbers
Stock “Loans” Ruled Sales
In three cases this summer, the Tax Court ruled against purported stock loans that it said were sales. One case involved millions of dollars in built-in gain and IRS-asserted deficiencies totaling $30 million for Denver multibillionaire Philip Anschutz. Two other cases involved participants in the Derivium “90% stock loan” abusive
Whose Goodwill Is It?
The U.S. District Court for the Eastern District of Washington recently held that goodwill created while a dentist was employed by his solely owned corporation belonged to the corporation and not to him. As a result, the dentist was required to characterize as a corporate dividend rather than a long-term
IRS Releases Some Annual Inflation Adjustments, Many Unchanged for 2011
The IRS released on Thursday its annual revenue procedure making inflation adjustments for various credits and other tax items (Revenue Procedure 2010-40). However, unlike in past years, the guidance does not include updated tax rate tables or updated amounts for the child tax credit, Hope scholarship and lifetime learning credits,
IRS Commissioner Predicts Relief From Testing and Continuing Education for CPA-Supervised Nonsigning Preparers
The IRS will likely provide relief from testing and continuing education requirements for nonsigning tax preparers working under the supervision of a CPA or other federally authorized tax practitioner, such as an attorney or enrolled agent, in a CPA or other professional firm, IRS Commissioner Doug Shulman said Tuesday. In
IRS Provides PTIN Guidance for Preparers Without a Social Security Number
In Revenue Procedure 2010-41, released on Tuesday, the IRS has provided a process for individuals without a Social Security number to obtain a preparer tax identification number (PTIN). Paid tax return preparers are required to register with the IRS and obtain a PTIN, and part of the PTIN registration process
Regulations Provide Guidance on Hybrid Pension Plans
On Monday, the IRS released final and proposed regulations providing guidance on so-called hybrid defined benefit pension plans (TD 9505 and REG-132554-08). The regulations deal with changes made by the Pension Protection Act of 2006 and the Worker, Retiree, and Employer Recovery Act of 2008. They generally apply to plan
IRS Rules That Mortgages Over $1 Million Can Be Deductible
The IRS has ruled that indebtedness incurred by a taxpayer to acquire, construct or substantially improve a qualified residence can constitute “home equity indebtedness” to the extent it exceeds $1 million, up to an excess of $100,000 (Revenue Ruling 2010-25). In the fact situation discussed in the ruling, an unmarried
IRS Issues Final Regulations on Stock Basis Reporting Requirements
The IRS issued final regulations on Wednesday regarding a new requirement for reporting of basis and other information by stockbrokers and mutual fund companies for most stock purchased in 2011 and all stock purchased in 2012 and later years (TD 9504). The final regulations implement a provision from the Energy
IRS Delays Mandatory W-2 Reporting of Health Care Coverage Costs
On Tuesday, the IRS issued a notice providing interim relief to employers regarding reporting the costs of group health plan coverage to employees (Notice 2010-69). Under the notice, notification to employees on Form W-2 will not be required for 2011. The IRS also posted a draft 2011 Form W-2 on
AICPA VP Testifies on Changes Needed to IRS Return Preparer Regulation Plan
Edward Karl, AICPA vice president–Taxation, testified at an IRS hearing on Friday about proposed amendments to Circular 230 that would put into place many parts of the IRS’ plan to register and regulate tax return preparers (REG-138637-07). The proposed regulations would clarify the definition of tax practice, establish a new
PTIN Registration Site Offline This Weekend
The IRS announced that its new online preparer tax identification number (PTIN) registration site will undergo system maintenance this weekend and be unavailable for use. The Service estimates that the site will be taken down at approximately 8 a.m. EDT Saturday, Oct. 9, and will remain unavailable until approximately 8
Line Items
IRS PROPOSES PTIN FEES The IRS proposed (REG-139343-08, issued July 23, 2010) to begin charging all authorized tax preparers a $50 user fee to obtain or renew annually a preparer tax identification number (PTIN). The fee would be on top of a fee charged by a third-party vendor that will
Jurisdiction Not Limited to Award Amount, Tax Court Says
The Tax Court ruled that an IRS letter denying a tax whistleblower’s claims was a “determination” giving the Tax Court jurisdiction to review the matter under IRC § 7623(b)(4). Thus, the court declared that its jurisdiction is not limited to the amount of an award but includes any determination by
Online Selling and Third-Party Network Reporting
The payment settlement reporting requirements of new IRC § 6050W, which go into effect next year, apply broadly to transactions conducted by debit or credit card, as well as third-party network transactions. While CPAs’ clients can easily understand how accepting payment cards at point of sale might affect them, those
IRS Issues Final Regulations on Tax Shelter Excise Taxes
The IRS and Treasury Department issued final regulations under IRC § 4965 for excise taxes on tax-exempt entities that enter into prohibited tax shelter transactions and on their managers who approve such transactions or have reason to know that they are prohibited tax shelter transactions. Certain tax-exempt entities such as
Features
SPONSORED REPORT
Get your clients ready for tax season
Help clients avoid surprises with year-end planning strategies for managing taxable income, maximizing deductions, and adjusting to OBBBA changes affecting individuals and businesses.
From The Tax Adviser
October 31, 2026
AI risks to the Sec. 7525 practitioner privilege
September 30, 2026
Navigating the QSBS rules in pass-through structures
September 30, 2026
Sec. 338(h)(10) elections in business acquisitions
August 31, 2026
