The Supreme Court upheld the mandatory repatriation tax as a valid exercise of Congress’s taxing authority. The Court did not reach the question of whether income must be realized to be taxable.
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Tax
Regs. cover green energy incentive wage and apprenticeship requirements
Under new final regulations issued by the IRS, taxpayers can generally increase the base amount of certain credits or deductions by five times when they meet prevailing wage and apprenticeship requirements.
IRS moves to end ‘shell game’ of basis-shifting transactions
The Service said it will release new proposed regulations and a revenue ruling to challenge the use of basis-shifting transactions used by complex partnerships in moves that could add over $50 billion to government coffers over 10 years.
IRS gives another limited estimated corporate AMT underpayment waiver
The IRS issued a notice extending earlier relief for a corporation’s failure to pay the part of estimated income tax attributable to the revised corporate alternative minimum tax.
9 months into ERC claim processing moratorium, still a waiting game
New employee retention credit (ERC) claims continue to be filed, and the IRS still has a backlog of claims from before a processing moratorium was announced in September. National Taxpayer Advocate Erin Collins says “soon” is the answer to when the moratorium will end. Meanwhile, some business owners sit and wait.
National taxpayer advocate: TikTok a difficult adversary for IRS
Speaking at ENGAGE, Erin Collins asks: How does the IRS fight bad tax advice on TikTok when employees are not supposed to access it?
Supreme Court: Insurance proceeds increase corporation’s estate tax value
In a unanimous decision, the Supreme Court holds that life insurance proceeds a corporation receives to fund a share redemption agreement increases the corporation’s estate tax value.
Expert warns: IRS has what it needs to pursue more audits
A speaker at AICPA & CIMA ENGAGE tells attendees that the IRS is paying higher salaries to attract midcareer workers as the agency increases audits.
Line items
Supreme Court to decide estate tax impact of life insurance in closely held businesses … Enforcement, voluntary programs yield over $1 billion from ERC claims … Werfel says digital initiatives can transform ‘iconically unpopular’ IRS … Federal court holds Corporate Transparency Act unconstitutional … Decision holding Corporate Transparency Act unconstitutional appealed
Criminally forfeited IRA distribution was constructively received and taxable
The Tax Court denies an incarcerated taxpayer’s arguments to the contrary.
IRS data reveals insights into collections, compliance, and criminals
A comprehensive exploration of the latest IRS data provides insights into compliance, revenue collection, and criminal activities.
Bias possible in IRS program for auditing refundable credit returns
The IRS said it agrees with the six recommendations from the Government Accountability Office to eliminate the bias.
IRS free filing program to become permanent with expanded scope
Commissioner Danny Werfel said the successful pilot program of Direct File encouraged the IRS to make the program available in all states and the District of Columbia.
AICPA makes recommendations to IRS on next Priority Guidance Plan
In addition to the guidance on the plan, the letter recommends that Treasury and the IRS continue pursuing tax simplification.
IRS warns about more tax scams
The IRS said scams involving the fuel tax credit, the sick and family leave credit, and household employment taxes led thousands of taxpayers to file inflated refund claims.
Regulations finalize PTIN fees for tax return preparers
The IRS was required to reduce the charge for preparer tax identification numbers after a federal court found the previous amount excessive. The final regulations adopt the text of interim final and proposed regulations issued in 2023 without change.
HSA inflation-adjusted maximum contribution amounts for 2025 announced
After steep increases for 2024, the HSA maximum contribution amounts allowed by the IRS still increase for 2025, but not by as much, as the rate of inflation slowed.
After April 15: Top-of-mind tax advocacy topics, including the ERC
An AICPA leader reflects on the end of tax filing season and on a recent comment by the IRS commissioner. She also looks ahead at key issues on the advocacy front. Read the Q&A or listen to the podcast episode.
Foreign trust transactions and large gifts addressed in proposed regs.
The proposed regulations implement Secs. 643(i), 679, 6039F, 6048, and 6677, which were added or modified to prevent efforts by U.S. taxpayers to use foreign trusts and offshore arrangements to avoid U.S. taxes.
Final regs. issued for new, previously owned clean vehicle credits
The final regulations, which the IRS issued Friday, also provide rules regarding the critical mineral and battery component requirements for the new clean vehicle credit, and they add a new test for mineral content.
Features
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4 ways solo practitioners can stand out
Five years ago, a grieving Angel Zhen started his own CPA firm with no clients and no revenue. Today, he has 300 clients, $600,000 in revenue and 12 weeks of annual vacation. In this JofA article, he shares how he set up his firm and how you could do the same.
From The Tax Adviser
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Current developments in taxation of individuals: Part 2
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