The number of companies using the five-story Ugland House in George Town, Cayman Islands, as their address. The office building was mentioned in several Senate committee hearings regarding U.S. tax compliance implications and tax havens. Source: Senate Finance Committee, http://finance.senate.gov .
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Tax
No “Alternatives” to Tax Lien Foreclosures
The IRS is not required to exhaust “alternative collection methods” before foreclosing tax liens, because IRC § 7403 contains no such requirement, a district court in Nebraska ruled. The court rejected the argument of taxpayer Jennifer Meisner to apply section 6331(j)(2)(D), which applies to levies, because levies and tax lien
Supreme Court to Hear Kentucky Muni Bond Case
The nation’s highest court agreed to hear a case that could decide whether the vast majority of states may continue giving discriminatory income-tax preference to in-state municipal bonds. In Davis v. Department of Revenue, 193 S.W.3d 557 (2006), the Kentucky Court of Appeals agreed with the taxpayers’ argument that Kentucky’s
Korb Reassures on FIN 48
The IRS recently released an internal memo written in March 2007 by Chief Counsel Donald Korb stating that documents prepared pursuant to FASB Interpretation no. 48, Accounting for Uncertainty in Income Taxes, are considered tax-accrual workpapers and thus are subject to the IRS’s “policy of restraint.” The IRS has a
Transitional Relief for Changes to Preparer Penalty
Transitional relief has been granted through the end of the year for changes to the tax return preparer penalty under IRC § 6694(a) that were enacted as part of the Small Business and Work Opportunity Tax Act of 2007. The changes originally were to take effect May 26. The act
Stakes Raised on Oversized Refund Claims
Taxpayers who receive “excessive” refunds can now be tagged with a 20% penalty on the overpayment. The provision is one of several revenue enhancers included in the recently passed Small Business and Work Opportunity Tax Act of 2007. The change to IRC § 6676(a) assesses the penalty on any claim
Securities Basis Reporting Aired
Requiring securities brokers to report basis on their customers’ transactions has received renewed attention in Congress as a way to help bridge the “tax gap.” Senate Finance Committee Chairman Max Baucus, D-Mont., and ranking minority member Chuck Grassley, R-Iowa, presented draft legislation in late May. Bills also have been introduced
Managed Accounts
EXECUTIVE SUMMARY A growing number of companies are beginning to offer employees professionally managed accounts for 401(k) assets. In these managed accounts, an independent investment manager handles investment decisions, makes portfolio changes as needed based on each participant’s specific needs and risk tolerance, and rebalances the
Is It Alimony?
In a ruling against the IRS, the Tax Court underscored that while alimony must be made under a divorce or separation instrument to be deductible, the payer doesn’t have to be legally obligated to make the payments. Under IRC § 71, cash payments made under a divorce or separation agreement
Put the Proof on Paper
A pair of recent Tax Court memos emphasized the longstanding rule of Welch v. Helvering, 290 U.S. 111 (1933), that taxpayers have the burden of proof when challenging an IRS determination. If the IRS audits a return, it is entitled to not take the taxpayer’s word on expenses, deductions and
Proposed New Form 990 Released
Form 990, Return of Organization Exempt From Income Tax, will have a new format the IRS hopes to roll out for the 2008 tax year, in the form’s first overhaul since 1979. The changes are designed to aid transparency, with the first page of the 10-page form (one more than
IRS Issues Guidance on Monetary Penalties
The IRS published guidance in Notice 2007-39 to outline how it will wield its new statutory authority to impose monetary penalties on taxpayer representatives for violations of Circular 230. The amendment to 31 USC §330 empowers the Service to levy monetary penalties for violations occurring after Oct. 22, 2004. The
AICPA Tax Division to Teach Quality Control
The AICPA Tax Division’s proposed Statement on Standards for Tax Services no. 9, Quality Control, will provide a basis of an educational effort by the Tax Division. The proposed standard was exposed for public comment in December 2005. After reviewing the comments, the AICPA Tax Executive Committee decided early this
Turn the Spotlight on Tax-Friendly Benefit Options
Young employees are in the dark when it comes to retirement planning, and as a result, potential tax savings are slipping through their fingers, according to a taxpayer survey by CCH and Harris Interactive. Employees ages 18 to 24 were least likely to use company-sponsored 401(k) plans—participation rates sit at
Counting Escrows
The First Circuit Court of Appeals has upheld the Tax Court in Burke v. Commissioner , 99 AFTR 2d 2007-941. In so doing, the courts underscored the IRS’s position that distributed income from a partnership must be recognized as taxable income even when it is held in escrow by the
Feeling the Tax Sting
Mutual fund investors were hit hard in 2006, paying the IRS more than $23.8 billion on their reinvested distributions. Equity fund shareholders paid more than 60% ($14.4 billion) of the total tax burden on their capital gains. Investment companies distributed $418.5 billion last year, surpassing the previous record high of
No Gain, Some Pain for Another Lottery Winner
The Second Circuit Court of Appeals joined other courts holding that a taxpayer’s sale of rights to future installments of lottery winnings is ordinary income and not capital gain. Shirley Prebola won $17.5 million in the New York State Lottery. The winnings were to be paid in 26 annual installments.
Look to Audit Bottom Line, Says IRS
Experience from its expanded number of audits of corporate returns will allow the IRS to work smarter in the future, the agency said, as it acknowledged spending more time on audits that came up empty of additional tax. The IRS rebutted a report in April by a research organization associated
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