The Joint International Tax Shelter Information Centre—an organization of tax administrators from Australia, Canada, the United Kingdom and the United States—recently focused on transactions by U.S. taxpayers with foreign counterparts to generate foreign tax credits. The IRS in response proposed amendments to regulations section 1.901-2, which targets transactions involving U.S.
Advertisement
TOPICS
Tax
E-Filing Surges
Electronic income-tax return filing rose in 2007 over the year before, the IRS said, surging as the April filing deadline approached. Late filers often owe the government money and tend to favor slower paper forms, the IRS said. But by early April, e-filed returns were up 6.2% over the same
CPAs Prescribe AMT Relief
Congress should repeal the individual alternative minimum tax (AMT) or at least reform it, said Joseph W. Walloch, incoming chair of the AICPA’s technical resource panel on individual income tax. Walloch, along with other CPAs and taxpayers, testified in March before a House Ways and Means subcommittee to the AMT’s
AICPA Criticizes Foreign Currency Regs
Proposed regulations amending IRC section 987 may frustrate the intent of the Tax Reform Act of 1986 and place an undue burden on taxpayers, the AICPA said. The new regulations establish a “foreign exchange exposure pool” method of reporting gain and loss transacted in a foreign currency. Comments developed by
IFRS: Coming to America
EXECUTIVE SUMMARY International Financial Reporting Standards (IFRS) are destined to be the lingua franca of the international accounting world. Approximately 100 countries already require, allow or are in the process of converging their national accounting standards with IFRS. FASB and the IASB have agreed to converge
Auditing
The PCAOB for a second time delayed application of Rule 3523, Tax Services for Persons in Financial Reporting Oversight Roles, to situations where firms provide tax services to a client before they become the client’s auditor. The audit independence rule, which forbids firms from providing tax services during an “audit
Heavy Price for Ignoring Levy Notice
In U.S. v. MPM Financial Group Inc., the Sixth Circuit scolded the defendant for exercising poor internal controls as it upheld a penalty for failure to comply with a notice of levy against one of its employees, who was also the corporation’s co-owner and president. Because the employer did not
No Penalty for BLIPS
In the widely reported case Klamath Strategic Investment Fund (see “Tax Matters,” JofA, March 07, page 72), the district court disallowed claimed losses on a finding that the transactions were shams and lacked economic substance. An important but less widely known aspect of the case was the court’s refusal to
Determining Basis for Gambling Losses
With the proliferation of legal types of gambling (lotteries, casinos, horse and dog racing, jai alai, bingo, etc.), many more taxpayers are in the (enviable) position of having to report winnings on their tax returns. While many taxpayers may generally know that they can deduct their losses
Report Says IRS Fails to Protect Sensitive Data
The agency tasked with processing more than 220 million tax returns annually is not doing an adequate job of protecting the sensitive personal financial information of the taxpayers submitting those forms, according to a report from the Treasury Inspector General for Tax Administration (TIGTA). TIGTA said IRS employees reported the
Stakes Increase as High-Profile Bills Move Through
The new House and Senate Democratic majorities started the year with aggressive agendas, passing several pieces of legislation in the first 100 hours. However, as the burden of being in the majority takes its toll, they are finding it increasingly difficult to reconcile the differing House and Senate versions of
New Law Provides AMT Relief
Individuals holding incentive stock options have historically faced a dilemma at tax time. If options are in the money, they may be subject to the alternative minimum tax (AMT) on paper profits even before selling their shares. If they sell their shares at a loss, their net
Pay Upfront on OICs
The IRS revised its offer-in-compromise (OIC) application package to reflect changes of the Tax Increase Prevention and Reconciliation Act of 2005. Form 656 includes a checklist designed to help taxpayers determine whether they are eligible to file an OIC before they prepare the form. Also, for OICs submitted after July
AICPA Criticizes Tax Patents
Congress should restrict patents on tax strategies or protect taxpayers and preparers from infringement actions arising from them, the AICPA told members of congressional committees. In letters to the House and Senate tax-writing and judiciary committees and a white paper, the AICPA said one government agency—the U.S. Patent and Trademark
Avoiding FASB 123(R) Pitfalls
EXECUTIVE SUMMARY FASB Statement no. 123(R), Share-Based Payment, poses a potential dilemma for companies with net operating losses (NOLs) that award nonqualified stock options (NQSOs) as compensation. If a company’s allowable tax deduction for stock option compensation exceeds the related book expense, it can realize an
35% Flat Tax Hits Non-CPAs
A C corporation that provides accounting services doesn’t have to be owned by or employ CPAs to be taxed at the flat 35% personal-services corporation rate of section 11(b)(2), according to a recent Tax Court ruling. In Rainbow Tax Service, Inc. v. Commissioner, 128 T.C. No. 5, the taxpayer was
Time to Rethink Your 401(k) Plan?
EXECUTIVE SUMMARY The PPA has made it easier for plan sponsors to automatically enroll employees in a retirement plan by eliminating the worry over state withholding laws. It delineates a new safe harbor automatic enrollment provision that starts the automatic deferral at 3%, raising it by
E-Filing Lags
Since about 54% of individual taxpayers e-filed in 2006, it seems unlikely that a congressionally mandated goal of 80% for this year will be met, the IRS Oversight Board said in its annual report to Congress. The board suggested extending the goal to 2012. E-filing declined in 2006 among individuals
Features
FROM THIS MONTH'S ISSUE
Want to thrive in an AI world? Power up your people skills
Learn how CPAs can strengthen their human relationships by developing their communication, curiosity, and self-awareness. Artificial intelligence can’t replicate these people skills.
From The Tax Adviser
April 30, 2026
Current developments in taxation of individuals: Part 2
April 30, 2026
