In a rare setback for the IRS in its litigation against lease-in, lease-out (LILO) tax shelters, the Court of Federal Claims held that an arrangement by Consolidated Edison Co. of New York (Con Ed) with an electric utility in the Netherlands should be respected for federal tax purposes because it
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Tax
2010: The Year of the Roth Conversion?
This year will be the Year of the Tiger, according to Chinese custom, but it also could be remembered by investors as the Year of the Roth Conversion, a decision that can have a large impact on investors’ ability to build wealth during their lifetime and preserve wealth for beneficiaries.
IRS Issues Regulations on Disclosure of Tax Return Information
On Tuesday, the IRS issued temporary and proposed regulations under IRC § 7216 that increase the circumstances in which tax return preparers can disclose or use certain limited tax return information (TD 9478 and REG-131028-09). The temporary regulations amend final regulations that were issued in 2008 and were effective Jan.
IRS Provides Guidance on Return Preparer Liability Under IRC Section 7216
On Wednesday, the IRS issued two revenue rulings (Rev. Ruls. 2010-4 and 2010-5) that provide guidance to tax return preparers on situations in which they will not be liable for civil or criminal penalties under IRC § 7216 for disclosing or using tax return information. IRC § 7216 prohibits a
Tax Court Accepts IRS Method for Determining Gambling Wins and Losses
The Tax Court held in a memorandum decision released Monday that taxpayers who were casual gamblers recognized wins or losses when they redeemed their tokens and that they could not net their wins and losses across the year (Shollenberger, TC Memo 2009-306). In this decision, the court accepted the IRS’
IRS Extends Moratorium on Tax Shelter Enforcement
IRS Commissioner Doug Shulman announced in a letter to Sen. Chuck Grassley, R-Iowa, that the IRS is extending until March 1, 2010, a moratorium on collection enforcement of the IRC § 6707A penalty for failure to disclose tax shelters and other reportable transactions. Shulman first announced the moratorium July 6
Regulations Proposed on Basis Reporting by Brokers
The IRS issued proposed regulations (REG-101896-09) on Wednesday relating to how securities brokers report sales to the IRS and how stock basis is determined. The regulations project also proposes to set a Feb. 15 deadline for brokers to supply certain information statements. The proposed rules reflect changes made in 2008
House Passes Financial Regulatory Reform Bill
House lawmakers voted Friday to approve The Wall Street Reform and Consumer Protection Act, a series of financial regulatory measures. The AICPA advocated for the profession on several provisions in the bill. The bill gives the PCAOB authority to inspect and regulate audits of all broker-dealers. It gives the PCAOB
Deadline for Retirement Plan Amendments to Conform to Recent Laws Extended
The IRS has extended by one year the deadline for retirement plans to make amendments required by the Pension Protection Act (PPA) and last year’s Worker, Retiree, and Employer Recovery Act (WRERA) (Notice 2009-97). The deadline is extended to the last day of the first plan year that begins on
Revised Statements on Standards for Tax Services Take Effect Jan. 1
The AICPA has released revised Statements on Standards for Tax Services (SSTS), whichbecome effective Jan. 1, 2010. The SSTS are enforceable standards of tax practice for AICPA members that address each member’s obligations regarding the following issues: The level of authority needed to recommend a tax return position or
IRS Issues 2010 Mileage Rates
The IRS announced Thursday (Revenue Procedure 2009-54) the standard mileage rates for computing deductible costs of operating an automobile that are paid or incurred on or after Jan. 1, 2010. For business use of an automobile, the rate is 50 cents a mile. For medical or moving expenses, it is
2009 Tax Software Survey
The JofA and The Tax Adviser conducted a survey of their readers to determine what aspects of their tax preparation software they like and what they dislike. The survey, which received 9,776 responses, was carried out in late June and early July 2009. Of the 13 products identified for the
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IRS ISSUES REGS ON SIX-YEAR LIMITATIONS ON BASIS OVERSTATEMENT The IRS issued proposed and temporary regulations (TD 9466, REG-108045-08) Sept. 24 to clarify that an overstatement of basis can create a substantial omission of gross income under IRC §§ 6229(c)(2) and 6501(e) for purposes of the six-year extended period for
When a Tax Return Is Not a “Return”
A taxpayer who does not comply with IRC § 6020(a) when filing late tax returns could lose the benefit of a bankruptcy discharge of taxes due on those returns. CPAs must be wary of this 2005 amendment to the Bankruptcy Code (USC Title 11) if a client has a history
A Limited-Time Opportunity for Small Business Stock
The American Recovery and Reinvestment Act of 2009 (ARRA) increased the exclusion amount for qualified small business stock (QSBS) from 50% to 75% (IRC § 1202). In addition, QSBS is currently subject to a lower inclusion rate for gains subject to the alternative minimum tax (AMT) under section 57(a)(7). However,
Underlying Assets Not Gift Tax Value of Interest in N.Y. LLC
In a taxpayer-friendly ruling, the Tax Court has held that a transfer of interest in a single-member limited liability company (LLC) should be valued for gift tax purposes as a transfer of an interest in the LLC rather than a transfer of its underlying assets. In 2000, Suzanne Pierre organized
IRS Expands Electronic Payment Options
With tax season about to start, practitioners should be aware of the various electronic payment options the IRS has introduced in recent years. EFTPS The IRS’ free Electronic Federal Tax Payment System (EFTPS) allows businesses and individuals to pay federal taxes via the Internet or over the phone. Tax payments
An Update on Accounting for Uncertainty in Income Taxes
Preparers of private company and not-for-profit organization financial statements will have to implement provisions of Topic 740 of the FASB Accounting Standards Codification (ASC) relating to accounting for uncertainty in income taxes (formerly FASB Interpretation no. 48, commonly known as FIN 48) for annual financial statements for periods beginning after
Requests for Tax Shelter Opinion Letters Denied
The Tax Court denied a partnership’s motions to compel the IRS to provide tax opinion letters related to all known “Son of BOSS” transactions, along with a list of law or accounting firms that have issued them. The court determined that the information requested by 3K Investments LLC (tax matters
Two Easements, Two Outcomes
The Tax Court decided two cases involving conservation easements with mixed results for the taxpayers. In one case, the court held that the taxpayer was entitled to a charitable deduction for easements on two properties, since the easements were exclusively for conservation purposes. According to the court, the easements preserved
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