Clients may not know how a structuring their company can affect them down the road.
In a move designed to fight taxpayer identity theft and tax fraud, the IRS will eliminate automatic extensions of time to file forms in the W-2 series, starting in 2017.
Long lead times, high upfront expenses, and frequent business acquisitions and dissolutions make applying Sec. 195 a special concern for these companies.
The Tax Court held that Regs. Sec. 1.482-7(d)(2), requiring entities to share stock-based compensation costs under qualified cost-sharing agreements, failed to meet the reasoned decision-making standard and was invalid.
Speaking at an IRS Nationwide Forum in Fort Washington, Md., the deputy director of the IRS Office of Professional Responsibility warned practitioners that they should exercise due diligence when advising clients on emerging tax issues.
The IRS issued temporary regulations designed to prevent corporations from avoiding gain on the distribution of appreciated property through the use of partnerships.
The bright-line test introduced in 2012 amended the existing rules that applied a facts-and-circumstances test.
The IRS Large Business & International (LB&I) Division issued guidance to its employees listing activities performed “at the retail level” that it said do not produce property that is “manufactured, produced, grown, or extracted,” as defined by Regs. Sec. 1.199-3(e).
In a speech to the AICPA’s spring Council meeting, Rep. Paul Ryan, chair of the House Ways and Means Committee, laid out his goals for tax reform and lower tax rates. He also called for the United States to adopt a territorial tax system.
The IRS issued revenue rulings on whether two transactions, one involving domestic entities and another involving both domestic and foreign entities, qualified as Section 351 exchanges followed by D reorganizations.
Proposed rules would define when investment income earned by a foreign insurance company would not be considered passive income in the determination of whether the company is a passive foreign investment company (PFIC).
IRS gives limited transition relief for employer payment plans and 2% S corporation shareholder arrangements.
IRS provides relief requested by AICPA and numerous others for accounting method changes.
The need to file Schedule UTP, Uncertain Tax Position Statement, may have taken many corporate taxpayers by surprise in 2014, since the asset threshold for compliance was lowered from $50 million to $10 million.
The IRS offers a test and safe harbor for qualifying dual-function internal-use software.
New figures for 2014 reflect the retroactive extension of bonus depreciation.
A taxpayer couldn’t prove his CPA had responded to an IRS letter assessing the 100% penalty for failure to pay payroll tax.
The IRS issued final and temporary regulations that clarify and simplify rules regarding broker basis reporting issued in 2013.
A long-haul truck driver who spent 358 days on the road during 2009 did not have a tax home that would permit him to deduct his travel expenses as unreimbursed business expenses.
The IRS asked for comments on a proposal to establish a free e-filing program for employment tax returns in an attempt to increase electronic filing of these returns by businesses.