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 -
News & Analysis as of

US Citizenship Renunciation Procedures in Canada

The US constitution protects a US citizen from automatic loss of citizenship. Expatriation can only occur through the voluntary, intentional commission of an expatriating act that is stipulated by statute. A person who...more

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

The Qualified Subchapter S Subsidiary Election – A Primer and Beyond

Mr. Brant’s article offers readers a broad overview of the QSub election and a review of the history surrounding its statutory creation. In addition, it provides a rather in-depth discussion of the QSub qualification...more

The End of Leveraged Partnership Transactions?

If a partner contributes property to a partnership, and within a two year period, receives cash from that partnership, the tax rules generally treat that as a disguised sale of property by the partner to the partnership. ...more

Former IRS Employee Reports to Prison for Identity Theft and Fraud

Nakeisha Hall was sentenced in federal district court in August to serve nine years and two months in prison after she plead guilty for crimes she committed while working for the IRS Taxpayer Advocate Service. Instead of...more

Received a Notice of Deficiency? NY IRS Attorney Explains What to Do

Under Section 6212 of the US Code, you will receive a Notice of Deficiency from the IRS when changes are going to made to your income tax return. Typically, the statutory Notice of Deficiency is sent after an audit. It can...more

IRS Allows Self-Certification For Waiver of 60-Day Rollover Requirement

On August 24th, the IRS released guidance that permits an automatic waiver of the sixty-day rollover period for retirement plan distributions by allowing individuals to self-certify that they qualify for the waiver under any...more

Intra-Family Loans: An Estate Planning Strategy in a Low-Interest Rate Environment

In the current economic environment, IRS-prescribed monthly interest rates for certain intra-family transactions are at historic lows. As a result, an excellent opportunity exists to transfer wealth to lower generation family...more

Making Lifetime Gifts Saves Federal Taxes

Lifetime Gifts Yield Estate and Gift Tax Savings - The federal gift tax annual exclusion currently allows each individual to give up to $14,000 each year to an unlimited number of donees – entirely free of tax. (Under...more

New Relief for Meeting the 60-Day Limit for IRA and Retirement Plan Rollovers

IRA and retirement plan rollovers are common occurrences, but they can be confusing. There a variety of rules and procedures which must be followed and mistakes may be costly. In addition to the potential for the rollover...more

Did You Know That Payroll Taxes Non-Compliance Can Get You Into TROUBLE?

S Corps are corporate entities through which the income and or losses of the entity pass through to its owner’s personal income tax return. It is estimated that 100% of the shares of approximately 70% of small businesses...more

IRS Finalizes Regulations Simplifying 83(b) Filing Requirements

On July 23rd of last year, I blogged on a set of proposed regulations eliminating the requirement that a taxpayer attach a copy of his or her Section 83(b) election to their individual tax return. This July, the IRS made the...more

Practice Aid – A Redlined Version of the Proposed Section 2701 and 2704 Regulations

These proposed regulations are difficult enough in substance to deal with, without having to piece together the changes that they make to the existing regulations. Maybe there is a redlined version out there already, but I...more

Thinking of Crowdfunding Your Project? Beware – the Taxman Cometh

The IRS Office of Chief Counsel recently released Information Letter 2016-0036 in response to questions regarding the taxation of crowdfunding revenue. In it the IRS concluded that crowdfunding revenue is taxable to the...more

IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return

The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted...more

IRS Proposed Regulations Attack Valuation Discounts for Family Transfers — The Clock Is Now Ticking

The U.S. Department of the Treasury and the IRS have just issued anticipated proposed regulations that, if made final, would severely limit the ability of taxpayers to transfer interests in family limited partnerships and...more

Proposed Treasury Regulations Provide Additional Flexibility, Clarity and Planning Opportunities to Sponsors of Deferred...

The IRS recently issued proposed regulations under Internal Revenue Code Section 457 that address, among other things, the interplay between Code Section 457(f) and Code Section 409A. Additionally, the IRS issued clarifying...more

Executrix Held Liable Under Federal Claims Statute For Actions Taken Prior to Appointment as Executrix

A decedent died while owing over $340,000 in unpaid federal income tax liabilities. His estate was insolvent. The assets of his estate consisted almost entirely of a 100% interest in one corporation and 50% of another...more

Personal Planning Strategies - August 2016

Low Interest Rates Yield Wealth Transfer Opportunities - Low interest rates can create wealth transfer opportunities. For various wealth transfer techniques, the IRS assumes that a certain minimum interest rate is in...more

IRS Wins Debt vs. Equity Case

A frequent area of dispute between taxpayers and the IRS is whether an indebtedness obligation should be treated as debt, or an equity investment, for income tax purposes. Taxpayers often seek debt treatment to obtain...more

IRS Provides Guidance for Making an 83(b) Election

On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more

The Cost of Clarity: IRS Issues Regulations Addressing Proper Treatment of Code Section 50(d) Income

On July 21, 2016, the IRS issued long-awaited regulations under Section 50 of the Internal Revenue Code (the “Code”) clarifying the manner in which “Section 50(d) Income” is to be recognized in lease pass-through investment...more

IRS Issues Proposed Rules on Income Inclusion under Section 50(d)(5)

The IRS just published long-awaited temporary regulations under section 1.50-1T governing the section 50(d)(5) income inclusion rules. These rules apply to lessees of investment credit property when the lessor elects to treat...more

Top 10 rules for compliant non-qualified deferred compensation

By Lori Jones Internal Revenue Code Section 409A regulates nonqualified deferred compensation (NQDC) plans and arrangements, which are commonly used to provide supplemental compensation to key executives. Complying with...more

Good News! New 409A Regulations (Yes, Really!) – Part 4: Getting Paid

On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more

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