Federal Taxes

News & Analysis as of

IRS Amends Circular 230 Regulations: Standard Tax Disclaimers Should Be Reviewed

The IRS amended the Circular 230 regulations in June, 2014. The main changes are the elimination of the “covered opinion” rules and the written disclosure requirement, as well as the expansion of requirements that apply to...more

No Disclaiming Federal Tax Liability

Chris owed money to the IRS, and had federal tax liens filed against him. He was also a 1/3 beneficiary of his mother’s estate. To avoid the IRS collecting against his share of the estate, Chris disclaimed his interest...more

S Corporations: The Basics

An S Corporation is the same as any other corporation except for the manner in which it is taxed. S Corporations generally do not pay federal income tax but pass the tax liability for their profits through to their...more

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

Sale of Clippers Will Cost Sterlings Significant Income Taxes

People who do not think that Donald Sterling is being impacted sufficiently by the NBA fine and being forced to sell the Los Angeles Clippers are not taking into account the significant federal and California income taxes...more

How the 2014/2015 Budget Measures up for Employers

The 2014/2015 Federal Budget (Budget) has introduced a number of important reductions, incentives and clarifications impacting employer initiatives, employee remuneration and benefits and the legal framework in which...more

Are You Curious How Your Tax Dollars Were Spent?

Your Federal Taxpayer Receipt is a tool launched by the White House that allows an individual taxpayer to see how his or her tax dollars were spent. On the website, simply insert the amount of social security tax, Medicare...more

Defending Federal and State Tax Audits For High-Income Taxpayers

In 2013 the IRS audited slightly over one taxpayer in nine[1] with an income of $1 million or more.[2] This audit rate represents a sharp 69 percent increase from the 6.42 percent audit rate that similar high-income...more

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

Victory for the Taxpayer in Validus: District Court Holds that Federal Excise Tax Does Not Apply to Retrocessions

On February 5, the U.S. District Court for the District of Columbia issued its opinion in Validus Reinsurance, Ltd. v. United States, which is the first case to involve a challenge to the IRS’s position on the “cascading”...more

The 13.3% Solution: of DINGs, NINGs, WINGs and Other ThINGs

Wealthy taxpayers have now experienced the impact of higher federal and state income tax rates for a full year. Many have created or would like to create trusts for their children and grandchildren, which also could be...more

McNees Insights - Asset Planning & Federal Taxation: Fall 2013

In This Issue: Timely Year-End Tax Planning Can Reduce Taxes; Income Tax Cost Basis Planning; and Marriage and Taxes in 2013. Excerpt from Timely Year-End Tax Planning Can Reduce Taxes - Year-end tax...more

Federal Tax Law Changes and Opportunities for Same-Sex Married Couples

What you need to know: As the result of the Supreme Court’s recent decision in United States v. Windsor and a subsequent ruling by the IRS, same-sex couples who are legally married in a jurisdiction that recognizes...more

California Reduces Section 409A Tax Penalty from 20% to 5%

Section 409A of the Internal Revenue Code of 1986, as amended (“Federal Section 409A”), imposes strict administrative and operational requirements on non-qualified deferred compensation arrangements, such as supplemental...more

Applicable Federal Rates – November 2013

Applicable Federal Rates – November 2013. Please see full charts for more information. ...more

Wage Garnishments: Know Your Limits

In trying economic times, the employees of automotive companies and Next-Generation manufacturers, like those of other companies, face financial hardship. In some cases, this may translate into these companies facing higher...more

The IRS and the Treasury Issue Ruling Recognizing Same-Sex Marriages Regardless of State of Domicile

On August 29, 2013, the U.S. Department of the Treasury (the "Treasury") and the IRS issued a revenue ruling that states that legally married same-sex couples will be treated as married for federal tax purposes, regardless of...more

IRS Recognizes Same Sex Marriages, Even If States Do Not

The Internal Revenue Service has announced that same sex couples legally married in a state whose laws authorize such a marriage will be deemed to be married for Federal tax purposes, even if they live in a state (such as...more

IRS, Treasury Recognize Same-Sex Marriages for Federal Tax Purposes

On August 29, 2013, the IRS released Revenue Ruling 2013-17, announcing that all legally married same-sex couples will be treated as married for Federal tax purposes, regardless of their state of domicile. At the same time,...more

IRS Announces All Same-Sex Marriages Recognized For Federal Tax Purposes

Yesterday the U.S. Department of Treasury and the Internal Revenue Service (IRS) announced that, as a result of the holding in U.S. v. Windsor that Section 3 of the Defense of Marriage Act (DOMA) is unconstitutional, the...more

Federal Income Tax Implications of Supreme Court Decision United States v. Windsor

The U. S. Supreme Court’s decision in United States v. Windsor, 570 U.S. ___ (2013) implicates important changes to the interpretation and administration of federal tax laws (including, income, gift and estate taxes). On June...more

Public Concerns Lead IRS to Offer Expedited Process for New Social Welfare Organizations

A wide array of organizations can qualify to be recognized as exempt from federal income taxes. Most noted of late are those organizations which are structured to “promote social welfare” and which can seek tax-exempt status...more

Appeals Court Reverses ERISA “Trade or Business” Ruling Favoring Private Equity Funds; Creates Uncertainty on Controlled Group...

In our November 9, 2012, client alert, we examined an apparent victory for private equity firms resulting from the District Court of Massachusetts decision that held that two related private equity funds were not liable on a...more

Make a New Year’s Resolution to Review Your Estate Plan in 2013

Each year, at this time, we remind our clients of the importance of keeping their estate planning documents up to date. With the avoidance of the tax side of the “Fiscal Cliff” and the passage of the American Taxpayer Relief...more

Some Federal, State, & Employment, Tax Considerations When Deciding on A Business Entity (LLC, Corporation or Sole Proprietorship)

The amount of taxes that you have to pay is one of the key reasons that individuals select one business entity type over another. The term “tax” though is a bit too general for a business as “tax” could refer to federal tax,...more

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