Tax

Since the Treasury Department adopted what are known as the check-the-box regulations, CPAs have been confident that unincorporated entities with two or more owners would be treated as partnerships unless they elected corporate treatment. The Circuit Court for the District of Columbia recently reversed a district court decision that an

IRC section 446(e) requires that a taxpayer secure IRS consent to change its method of accounting. Treasury regulations section 1.446-1(e)(2)(i) specifies that a taxpayer do this before computing its income under the new method. The rule also requires a taxpayer to file form 3115 with the IRS commissioner during the

Shareholder Legal Fees W ith the increased number of legal problems corporate officers, directors and shareholders face, it’s important to understand the correct tax treatment of legal fees a corporation pays on their behalf. Kenneth Guarino created Capital Video Corp. to distribute pornographic videotapes. Because he was worried organized crime

Under IRC section 7491, in any court proceeding the IRS has the burden of proof with respect to any factual issue relevant to determining a taxpayer’s liability for any income, self-employment, gift, estate and generation skipping transfer taxes if The taxpayer introduces credible evidence with respect to the issue. The

The IRS launched an amnesty program in January for taxpayers who, by means of offshore credit card accounts, evaded taxation of reportable income ( www.irs.gov/pub/irs-drop/rp-03-11.pdf ). Under the offshore voluntary compliance program, such taxpayers are responsible for back taxes, interest and certain accuracy or delinquency penalties. They also must identify

Under IRC section 1041, taxpayers recognize no gain or loss on property transfers between spouses during marriage or related to a divorce. The section’s intent is to treat spouses as a single economic unit and defer (but not eliminate) any tax on appreciation until property is transferred to a third