Federal Taxes

News & Analysis as of

New Legislation Makes Sweeping Changes Impacting All Partnerships

All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

IRS Issues Proposed Regulations to Accommodate Obergefell

On October 21, 2015, the IRS issued proposed regulations to clarify the treatment of same-sex spouses for federal tax purposes. By way of background, in 2013, the United States Supreme Court held in United States v. Windsor...more

Immigration and Taxation: Tools for Navigating Through Alien Territory

A client recently asked if a foreign national employee was subject to federal withholding taxes. Naturally, since the question involved the U.S. tax code the answer, like the code, is complicated. Fortunately, the IRS has...more

How Do an Estate's Debts Get Paid?

An executor is the person responsible for managing the administration of a deceased person's estate. One of the executor's main jobs is to pay people or institutions to whom the estate owes money -- the estate's creditors....more

ALJ Determines Taxpayer Settlement With the Internal Revenue Service Does Not Need to Be Reported to New York State

Taxpayers tend to face a difficult road when litigating tax disputes. We recently wrote about that here. It can be even more challenging, and costly, for taxpayers when they have to deal with more than one taxing authority on...more

Tax Law Blog: National Society of Accountants Proposes a Tax Practitioners Bill of Rights

With the approach of our nation’s independence day, we are reminded of the values on which our country was founded: basic freedoms provided to all under the first ten amendments of the Constitution. Life, liberty, and the...more

Innocent Spouse Relief and Recent Guidance

Generally, when you and your spouse file joint income tax returns, the law makes both you and your spouse responsible for the entire tax liability. This is called joint and several liability. Both spouses remain 100 percent...more

Don't be Fooled by the Name... The Small BREW Act Could Have a Big Impact on Craft Breweries

The Small Brewer Reinvestment and Expanding Workforce Act, known as the "Small BREW Act", is bipartisan legislation introduced to Congress in early 2015. The overall goal of the Small BREW Act is to revamp the federal excise...more

Coming to America (for Business) - Using the L1 Visa as an Alternative to EB 5

Overview - As a long term veteran of the financial services industry, I have learned that in many cases, people do not “buy” a product or service but instead are “sold”” the product or service that the advisor is...more

As Expatriations Increase, Potential Relief for “Accidental” U.S. Citizens

According to Treasury reports, 3,417 U.S. citizens relinquished their U.S. citizenship in 2014, which is more than the number of expatriations reported in prior years. As required by law, the Treasury publishes a quarterly...more

Obama Budget Proposal Would Provide Relief for Certain Accidental Dual Citizens

A provision contained in the Treasury’s green book explaining President Obama’s 2016 budget proposals may provide U.S. tax and reporting relief for certain dual citizens. An individual can become a U.S. citizen at birth...more

Morrison & Foerster Quarterly News Tax Talk - Volume 7, No.4 January 2015

In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more

Tax Alert: Three Critical Letters from the IRS - Why not to ignore them, what they mean and how to respond

All correspondence from the Internal Revenue Service should be taken seriously; however, some letters and notices have more legal consequences than others....more

The Individual Taxpayer Implications of the Tax Extenders in H.R. 5771

Every year for the past several years, Congress has passed a series of what are referred to as "tax extenders" - reinstatements of tax deductions and credits that have expired before the current tax year. It did so again in...more

Spotlight On Federal Tax Developments In 2014

This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more

IRS Guidance on Windsor Decision May Require End-of-Year Amendments for Qualified Retirement Plans

Earlier this year, the IRS published updated guidance on the application of the Supreme Court’s decision in United States v. Windsor to qualified retirement plans. In Windsor, the Court held that the Defense of Marriage Act’s...more

Federal Tax Lien Did Not Survive Death of Joint Tenant

Two individuals (Cunning and Wren) acquired real property in the U.S. Virgin Islands as joint tenants with rights of survivorship (JTWROS) in 2005. In 2010 the IRS filed a federal tax lien against Cunning in the U.S. Virgin...more

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

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