The IRS issued final regulations Tuesday governing the payment of tax liabilities in installments (TD 9473). The regulations reflect changes to the law made by various acts going as far back as 1996. IRC § 6159 allows taxpayers who cannot pay their tax liabilities in full an option to enter
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Tax
IRS Releases Guidance on Expanded NOL Carryback Rules
The IRS on Friday provided guidance on the new expanded five-year net operating loss (NOL) carryback rules, which were recently amended by the Worker, Homeownership, and Business Assistance Act, PL 111-92. The guidance is contained in Revenue Procedure 2009-52, and it explains how a taxpayer elects to carry back an
Tax Court Amends Rules to Allow Electronic Filing
The Tax Court has amended its procedural rules, effective Jan. 1, 2010, to allow electronic filing of documents submitted to the court (Tax Court Rule 26). The court set up a pilot electronic filing program in 2005. In 2008, the court added an electronic document access system to its Web
UBS Targets Come Into Focus
The IRS has released the selection criteria for identifying holders ofaccounts with Swiss bank UBS under a U.S. settlement agreement with the Swiss government negotiated in August. Under the agreement, UBS will turn over information concerning approximately 4,450 accounts for investigation. IRS Commissioner Doug Shulman also recently announced that about
IRS Pilot Program Will Allow Truncated Social Security Numbers on Information Returns
The IRS on Thursday announced a pilot program aimed at deterring identity theft (Notice 2009-93). Under the program, filers of certain paper information returns will be allowed to truncate the payee’s Social Security number on the payee statement. The change affects statements for 2009 and 2010. Only paper payee statements
Economic Optimism Levels Off, Execs Concerned About Government Policies
Optimism among CPA financial executives about the U.S. economy flattened after two quarters of improvement as managers paid more attention to potential challenges and concerns associated with the federal budget deficit, tax reform and regulatory requirements, according to a survey released Monday. Results from the Economic Outlook Survey Q4 2009,
President Signs Military Spouses Residency Relief Act
President Barack Obama signed into law the Military Spouses Residency Relief Act (PL 111-97), which will ensure that the spouses of military personnel who move because their spouse is posted for military duty will be treated as not having changed residency for tax purposes. Under the act, the fact that
President Signs Unemployment Bill With Tax Items
On Friday, President Obama signed into law a bill that includes changes to the first-time homebuyer credit, increased NOL carrybacks for small businesses, and mandatory e-filing for most tax return preparers. The bill cleared Congress on Thursday. The Senate had unanimously agreed to the bill, the Worker, Homeownership, and Business Assistance
Court Negates Tax Planning Transaction
A district court held that a partnership’s reported capital loss stemming from nonperforming loans lacked economic substance and denied the claimed tax benefits. D. Andrew Beal owned a bank that was in the business of acquiring nonproducing loans (NPLs) at extreme discounts. With an associate and China Cinda Asset Management
Final Regs Issued on E-Postcards
The Pension Protection Act of 2006 introduced a new notification requirement for small tax-exempt organizations that are not required to file an annual information return under IRC § 6033(a)(1). In July, the IRS released final regulations spelling out what small tax-exempt organizations must do to meet this requirement. Practitioners should
Accountable Plan Reimbursements for Tools and Equipment
In a recent private letter ruling, the IRS clarified how employer reimbursement of employee expenses for tools, equipment, training or certification required as a condition of employment may qualify as an accountable plan under IRC § 62. Reimbursements under an accountable plan are excluded from gross income of employees and
Line Items
FIRST CIRCUIT DENIES TEXTRON WORK PRODUCT PRIVILEGE In a 3-2 decision, the First Circuit Court of Appeals overturned its earlier three-judge ruling and a district court to hold that the work product doctrine did not protect from IRS summons the tax accrual workpapers of aviation and industrial conglomerate Textron Inc.
Application of Six-Year Statute of Limitations Denied Again
The Tax Court, whose denial of a six-year statute of limitations in Bakersfield Energy Partners had been recently upheld by the Ninth Circuit, held in two more cases that an overstatement of basis did not allow the extended assessment period for a substantial omission of gross income under IRC §
Qualifying Child Definition Amended
The Fostering Connections to Success and Increasing Adoptions Act of 2008, PL110-351, made several changes to the qualifying child (QC) definitions effective for tax years beginning after Dec. 31, 2008. Section 501(a) of the act amended the age requirement (IRC § 152(c)(3)) to also require the QC to be younger
Salaries a BIG Offset
C corporations that elect S status are often subject to the built-in gains (BIG) tax under IRC § 1374. One of the aspects of the BIG tax that can be a trap for the unwary is the treatment of accounts receivable for cash-basis corporations. The fair market value of accounts
IRS Not Limited to Three Years for FPAA
The Fifth Circuit held that IRC § 6229(a) sets no deadline by which the IRS must issue an FPAA (final partnership administrative adjustment). Its interpretation of the relationship between the limitations period in sections 6501(a) and 6229(a) mirrors that of the Tax Court, the D.C. Circuit and the Federal Circuit
Tax Consequences of Mortgage Discharge
In the current real estate climate of decreased property values and excess inventories, many rental property owners are facing reduced cash flows due to vacancies. At the same time, the fair market value of their property may be close to or even less than the amount owed on the mortgage
“Unforeseen Circumstances” Exclusion From Gain on Sale of Home
Despite the recent downturn in the American housing market, one of the highest-value assets owned by most taxpayers remains their home. While many taxpayers have seen the value of their home decline, those in locales where home values have remained relatively strong—such as parts of some Southern and Midwestern states—could
Highlights
FASB issued Accounting Standards Update (ASU) 2009-06 to provide additional implementation guidance on accounting for uncertainty in income taxes and to eliminate the disclosures required by FASB Accounting Standards Codification (ASC) Paragraphs 740-10-50-15(a) through (b) for nonpublic entities, including pass-through and not-for-profit entities. The new guidance involves requirements under what
Unrelated Child as a Qualifying Relative
One requirement for claiming a qualifying child (QC) for purposes of the dependency exemption deduction is that the child must be related to the taxpayer, that is, the taxpayer’s child (including stepchild or foster child), sibling, half-sibling, step-sibling or descendant of any of them (IRC § 152(c)(2)). However, dependents alternatively
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