The IRS announced Tuesday that it is considering making changes to how business taxpayers report uncertain tax positions (Announcement 2010-9). Specifically, the IRS said it is developing a schedule that certain businesses would be required to use to disclose uncertain tax positions on their returns annually. The IRS plans to
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Tax
Swiss Court Halts Release of Some UBS Account Holder Data
A Swiss court has held that the Swiss bank UBS does not have to hand over to the IRS confidential data on 26 accounts under a settlement agreement between the United States and Switzerland negotiated in August 2009. Under the agreement, UBS is supposed to turn over for investigation information
IRS Designates Haiti Earthquake as “Qualified Disaster”; President Signs Haiti Donation Bill
On Friday, the IRS designated the earthquake in Haiti as a “qualified disaster” for purposes of IRC § 139 (Notice 2010-16). As a result, victims of the earthquake who receive qualified disaster relief payments will be able to exclude those payments from income. The notice also allows employer-sponsored private foundations
Senate Passes Haiti Assistance Income Tax Relief
The Senate on Thursday passed by unanimous consent the Haiti Assistance Income Tax Relief Act (S. 2936). The Senate bill was identical to H.R. 4462, passed by the House on Wednesday. The legislation now goes to President Barack Obama for his signature; he is expected to sign it this week.
House Unanimously Passes Haiti Donation Bill
The House of Representatives on Wednesday unanimously passed a bill that would allow taxpayers to accelerate deductions for charitable contributions made for relief of victims of the earthquake in Haiti (HR 4462). Under the bill, taxpayers could deduct donations made in 2010 on their 2009 returns. Donations covered by the
IRS Updates Method Thresholds for Vehicle Fringe Benefits
The IRS has updated for 2010 (Revenue Procedure 2010-10) the maximum allowable fair market value (FMV) of an employer-provided vehicle for which the cents-per-mile and fleet-average rules may be used in determining the value of an employee’s personal use of the vehicle. For passenger automobiles, the new maximum FMV is
Tax Season Starts; IRS Releases Homebuyer Credit Form
The IRS started accepting e-filed tax returns on Jan. 15, marking the official start of tax season. The IRS’ popular Free File program also started accepting returns on Friday. However, as usual, W-2 and 1099 forms are generally not due to taxpayers before Feb. 1, so many taxpayers will not
Taxpayer Advocate Urges Better IRS Service
A report examining problems taxpayers encounter with the IRS found that the Service’s collection practices may harm long-term taxpayer compliance and are not supported by reliable data. The IRS also faces challenges in providing core services such as meeting the demand for telephone assistance, National Taxpayer Advocate Nina Olson said
IRS Proposes New Requirements for Return Preparers
The IRS on Monday announced plans to require mandatory registration of all paid, signing tax return preparers as well as competency testing and CPE requirements for preparers other than CPAs, attorneys or enrolled agents. The plan also calls for extending Circular 230’s ethics rules to all return preparers. Following a
Numerous Tax Provisions Expired at End of 2009
The ringing in of the new year at midnight on Dec. 31 also signaled the expiration of several tax provisions. The biggest was the estate and generation-skipping tax regime, which is repealed for 2010. Various bills have been introduced that would revive the estate tax in its 2009 form, but
Tax Season Kicks Off
Following a flurry of tax legislation that enacted changes for tax years beginning in 2009, this tax season requires heightened attention to make sure your clients don’t miss any of the new and extended deductions and credits to which they’re entitled. Most of the changes for 2009 were directed at
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SINGLE-EMPLOYER DEFINED BENEFIT PLANS GET GUIDANCE The IRS issued final regulations to provide guidance on funding requirements affecting single-employer defined benefit pension plan sponsors, administrators, participants and beneficiaries. The regulations in TD 9467 concern (1) the determination of the value of plan assets and benefit liabilities for purposes of the
Mark J. Hamlin, CPA, PC
Back row, from left: Sindy Pfaab, Tina James and Sissie Kipp. Front row, from left: Jena Bippert, Mark Hamlin and Peggy Piletere. A successful business doesn’t happen through wishful thinking. It takes a lot of hard work to make your dream come true. I always knew I wanted to own
Post-Mortem Tax Lien Is Valid
The IRS may recover a 100% IRC § 6672 trust fund penalty from any responsible person who acts willfully in failing to pay over to the government taxes withheld from employees. If the responsible person dies after the assessment but before the penalty is paid, the Tax Court held, a
Family Partnership Rules Applied in TIFD III-E Remand
In a case reversed and remanded by the Second Circuit, the U.S. District Court in Connecticut again held that a General Electric subsidiary could treat Dutch banks’ interests as partnership equity rather than debt. In so doing, the district court in the long-running TIFD III-E case again sided with the
Series LLCs: Pros and Cons of a Growing Trend
Eight states allow the formation of series LLCs (Delaware, Illinois, Iowa, Nevada, Oklahoma, Tennessee, Texas and Utah). A series LLC consists of a “master” LLC with one or more series of members, managers, interests or assets. Although contained within the master LLC, each series can have separate rights, powers and
Applying for a Private Letter Ruling
When a transaction requires greater certainty or when relief is sought for a difficult tax situation, applying to the IRS for a private letter ruling (PLR) can provide interpretation and application of law and regulation with respect to that taxpayer the Service will follow, within certain conditions and limitations. Here’s
Roth IRA an Ineligible S Corp Shareholder
The Tax Court decided 11–4 that an S election was automatically terminated because the corporation’s sole shareholder was a Roth IRA. The case was said to be a test case for a number of similar ones before the court. Taproot Administrative Services Inc., a Nevada corporation, was fully owned by
Waiving the 60-Day IRA Rollover Rule
Onerous consequences can result when taxpayers fail to follow through with an IRA tax-free rollover. Generally, the entire amount distributed from an IRA or other qualified trust or eligible retirement plan must be deposited in another such account within 60 days. Otherwise, it is included in the taxpayer’s gross income
Credit Card Fees Are OID
The Tax Court held that credit card “interchange” fees received by subsidiaries of credit card issuer Capital One resembled interest that increased or created original issue discount (OID) related to the company’s pool of credit card receivables. As OID, a daily amount was properly included in income over the life
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