A second taxpayer’s captive fails to qualify as an insurance company.
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Tax
How TIGTA stymied an IRS impersonation scam
Learn how authorities tracked down an IRS impersonation scam that allegedly stole “hundreds of millions of dollars” by phone.
S corporation shareholder may not revoke tax election
The Tax Court declines to create a precedent and allow an individual S corporation shareholder to unilaterally and retroactively revoke the corporation’s election.
Supreme Court overturns Quill’s physical presence requirement
States asserting nexus for sales taxes now have freer rein.
Profit motive key in hobby loss cases
Tax Court cases evaluate the nine-factor test in Regs. Sec. 1.183-2 for determining when losses may be deducted.
Deemed personal exemption amount introduced for various tax benefits
The IRS issued guidance on how it intends to interpret the exemption amount in tax years 2018 through 2025 in determining who is a qualifying relative for purposes of the various Code provisions that refer to the definition of a dependent in Sec. 152.
Proposed rules would curb avoidance of SALT deduction limit
Here is what practitioners need to know about the IRS’s proposed rules that would curb the deductibility of charitable contributions that qualify for state and local tax credits.
IRS provides initial guidance on new Sec. 162(m)
The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.
D.C. Circuit upholds IRS unenrolled tax preparer program
The Court of Appeals for the D.C. Circuit held that the AICPA had standing to challenge the IRS’s Annual Filing Season Program for unenrolled tax preparers but further held that the program did not violate the Administrative Procedure Act.
Qualified business income deduction regs. proposed
The IRS issued guidance on the new Sec. 199A deduction for qualified business income in the form of proposed regulations and a separate notice on how to calculate W-2 wages for those purposes.
Final regs. govern who can be a partnership representative
The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.
Ninth Circuit withdraws Altera opinion
The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”
IRS issues proposed regs. on 100% bonus depreciation
The IRS issued proposed regulations providing guidance on Sec. 168(k), which was amended by P.L. 115-97, known as the Tax Cuts and Jobs Act, to increase the allowable first-year depreciation deduction for qualified property from 50% to 100%.
Equitable recoupment doctrine applies to employment tax deposit
The taxpayer exercised ordinary business care, but its payroll taxes were applied to the EIN of a predecessor entity.
Proposed regs. address several transition tax issues
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
2018 tax software survey: Individual product survey responses
Online-only: Contact information, basic packages and their features are shown below for the top seven products in the survey.
Line items
Select Check is now Tax Exempt Organization Search … New FASB and IFRS standards get method change procedure … Rev. Proc. 2018-25 updates passenger auto depreciation, lessee income inclusion for TCJA
Volunteer board member of not-for-profit may assert reasonable cause for unpaid payroll taxes
A district court holds that reasonable cause remains an issue.
IRS to clarify rules on payments in lieu of state and local taxes
The Service warns that a substance-over-form recharacterization may ensue.
SEPs: Simple but not always optimal
Simplified employee pension (SEP) plans can be attractive in the short term but over the long term can be expensive, inefficient, and inflexible.
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