News & Analysis as of

Income Taxes Internal Revenue Service

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Applicable Federal Rates - July 2017

by Charles (Chuck) Rubin on

Please see full charts below for more information....more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

by Foodman CPAs & Advisors on

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Estate Planning and Prenuptial Agreements: Tax Implications of Alimony

by McNair Law Firm, P.A. on

When contemplating marriage and estate planning, frequently, individuals will enter into prenuptial (premarital) agreements to address their rights and obligations during the marriage and in the event of a divorce or death. A...more

IRS Re-Releases Partnership Audit Regulations

The IRS has released proposed regulations implementing the new centralized partnership audit rules. These regulations are virtually identical to the regulations that were released and then pulled in January of this year. ...more

IRS Reminds U.S. Taxpayers Living Abroad of Misc. Filing Due Dates and Filings

by Charles (Chuck) Rubin on

In News Release 2017-105, the IRS reminded U.S. taxpayers living abroad: The extended due date, if the taxpayer had his or her tax home and abode abroad on the original due date, is June 15. But interest on taxes runs from...more

What Do You Do If You Receive A Notice From The IRS That Your Tax Return Is Under Audit?

by Dickinson Wright on

Depending on the amount that may be at issue, call a tax lawyer immediately. A tax lawyer that has handled audits before is able to provide important strategy and structure to the audit that will present your case in the...more

Filing Your Own Return

by Moskowitz LLP on

In our last post, we reviewed the main advantages and disadvantages of joint tax returns for married couples. This post will focus on when a married couple should consider filing separately, and special considerations if they...more

The Joint Tax Return

by Moskowitz LLP on

IRS data indicates that over 95% of married couples file jointly – and for most, but not all, couples this makes good economic sense. In this two-part series, we will discuss the advantages and disadvantages of filing joint...more

Section 83(b) Elections Add Value To Equity Grants

by Cole Schotz on

Contractors, advisers, and employees (collectively, “Service Providers”) who receive property that is non-transferrable or subject to a substantial risk of forfeiture must generally defer their income recognition until those...more

Wealth Management Update - May 2017

by Proskauer Rose LLP on

May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

Treating Partners as Employees – Overview and Update

by Ballard Spahr LLP on

Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

Structuring A Parking Reimbursement Plan As A Taxable Or Tax-Free Fringe Benefit

by Dickinson Wright on

In Information Letter 2017-0007, the IRS analyzed an employer’s parking reimbursement arrangement and concluded that it was not a tax-free fringe benefit. ...more

With Tax Day Nearly Behind Us, Justice Department Pivots to Warnings About Employment Tax Violations

by Fox Rothschild LLP on

Following a relentless flurry of press releases announcing criminal charges against tax evaders in the run up to today’s tax filing deadline, the Justice Department wasted no time in turning its attention to its next target:...more

Government Refuses to Define "willfulness" for FBAR Purposes

by Sanford Millar on

Whether a taxpayer's conduct in failing to report foreign financial accounts is "willful" or "non-willful" makes a huge difference in penalty determination. However the government refuses to publish a definition of...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time

by Fox Rothschild LLP on

With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release entitled “With the...more

Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

IRS Warns Employers of Dangerous Email Scam

by Snell & Wilmer on

The IRS has recently warned employers of another scam targeting employee information. The IRS has learned that scammers are posing as internal executives and are requesting Forms W-2 and Social Security Numbers from payroll...more

Creating Non-Taxed “Previously Taxed Income”: The Ultimate Pre-Immigration Strategy

According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population. The countries from which the largest numbers of these individuals...more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

Is your Tax Preparer qualified to do your Return? Beware of Tax Preparers without a Preparer Tax Identification Number (PTIN) or...

by Foodman CPAs & Advisors on

Do you think that you have hired the right Tax Preparer to prepare your Taxes? Tax Season is here and many Tax Preparers portray themselves as “Qualified”. Tax Preparers have different levels of skills, education and...more

The Importance of Defensive Tax Planning and Defensive Tax Return Preparation

Executive Summary: The Importance of Defensive Tax Planning - Tax reform is in the news again. But until we achieve significant tax reform it is essential that individuals, trusts and estates, and businesses with incomes...more

Do you have to file a gift tax return (Form 709) for 2016?

by Dickinson Wright on

If you made a gift to one individual in excess of $14,000 during 2016 (or $28,000 if you are married and you and your spouse agreed to "gift split"), then you will likely be required to file a gift tax return....more

Charitable Contributions: Acknowledgements, Appraisals and the IRS's Strict Rules: Tax Update, Volume 2017, Issue 2

by Pepper Hamilton LLP on

Tax season has begun, and it is crucial for any taxpayer claiming a charitable contribution deduction to be aware of the acknowledgment rules. Before the taxpayer files a tax return claiming a charitable deduction of $250 or...more

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