News & Analysis as of

Proposed Section 752 Regulations and LIHTC Transactions: Part II

In a previous post earlier this week, I described the proposed regulations under Section 752 of the Internal Revenue Code (the “Proposed Regulations”), and in particular, the proposed changes to the rules regarding the...more

Final Regulations Issued For Investment Advisory Fees and Other Costs Incurred By Trusts and Estates Subject to the 2-Percent...

On May 8, 2014, the Internal Revenue Service published final Treasury Regulations, §1.67-4, prescribing when costs incurred by estates or nongrantor trusts are subject to the 2-percent floor for miscellaneous itemized...more

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more

Tax Reform Proposal Takes Aim at Executive Compensation

On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more

IRS Signals a Potential End to Its Administrative Pursuit of the Separate Account DRD

On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more

Temporary vs. Indefinite – Lodging Expenses Away From Home

A taxpayer who travels away from his tax home overnight on business can deduct 50% of meals and 100% of lodging costs. A taxpayer’s “tax home” is located at (1) his regular or principal (if more than one regular) place of...more

Family Mortgages Come Under IRS Scrutiny

The IRS insists that i’s must be dotted and t’s crossed before the IRS will allow taxpayers to deduct mortgage interest on a “qualified residence.” If the formalities are not observed, the debtor may be denied a deduction...more

Tax Tip: Don't Lose Your Charitable Deduction for Lack of Paperwork - A message from tax attorney Paul Topolka, former District...

Charitable contributions are only deductible if you itemize and have the proper substantiation. For cash contributions of less than $250, you must have either a cancelled check/credit card receipt or a written...more

Same-Gender Marriage Implications for Employee Benefit Plans

In the summer of 2013, the Supreme Court issued a decision in U.S. v. Windsor, striking down a key provision of the Defense of Marriage Act (DOMA) and eliminating the requirement that federal law recognize only marriages...more

Labor And Employment Law 2013: A Year-End Review

I. New Laws and Regulations - A. Federal - Following U.S. Supreme Court Decision, Federal Agencies Extend Definition of “Spouse” to Persons in Same-Sex Marriages. In United States v. Windsor, 133 S. Ct. 2675...more

Equal Tax Treatment for Same-Sex Couples in the Wake of Recent Supreme Court Ruling and IRS Guidance

Same-sex marriages now are being recognized under federal tax law for the first time. In June 2013, the Supreme Court released its decision in United States v. Windsor, 530 U.S. 12 (2013), declaring Section 3 of the federal...more

Direct Sellers, Be Prepared for Tax Season! Understand Network Marketing and Taxes for 2013!

Tax season is right around the corner for direct sellers. Are you prepared? Consultants, have you kept track of your IRS tax deductions? Did you know that you can deduct such expenditures as meals, entertainment, home...more

Contingencies on Employee Bonuses Delay Employer’s Tax Deduction According to IRS Chief Counsel Memo

An employer cannot deduct cash bonuses in the year in which its employees perform the services giving rise to the bonuses, but must wait until the following year when the bonuses are paid, under bonus plans with several...more

New IRS Guidance on Same-Sex Spouses and Cafeteria Plans

Action by December 31st Required for Safe Harbor - Yesterday, the IRS issued specific guidance on how employers can address issues arising from the change in tax treatment for same-sex spouses under cafeteria plans. ...more

Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of IRS Offshore...

Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more

High Net Worth Family Tax Report, Vol. 8. No. 4 -- December 2013

IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages - In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more

Too Much Discretion With Respect To Annual Bonuses May Cause Deferral Of The Employer’s Deduction

In an IRS Field Attorney Advice Memorandum (FAA 20134301F) dated September 18, 2013, the IRS Office of Chief Counsel reviewed several common bonus plan designs in connection with a request for an opinion with regard to the...more

Is Your Hedge Fund a Trader or Investor?

Hedge fund managers should be aware of two recent U.S. Tax Court memorandum decisions that shed further light on when a taxpayer, such as a hedge fund, is considered to be a "trader" or "investor" for tax purposes -- a...more

Wealth Management Update - November 2013

Federal Exclusion from Gift, Estate and Generation-Skipping Transfer Taxes Increases to $5,340,000 in 2014 - In Revenue Ruling 2013-35, the IRS announced certain inflation adjustments to tax exemptions and deductions....more

Top 3 Tax Mistakes

There are a lot of ways to get into hot water with state and federal revenue regulators. But, in my experience, three mistakes are most common. ...more

All Federal Benefits Apply To Same-Sex Marriages

Recently, the U.S. Supreme Court ruled unconstitutional Section 3 of the Defense of Marriage Act (DOMA), which, for federal purposes, defined marriage as between one man and one woman. United States v. Windsor, 570 U.S. ____...more

IRS Issues Updated Guidance for Vehicle Donations

We’ve all heard and read the radio and newspaper ads that encourage donors to contribute their vehicles to charity. The advertisements attempt to convince donors to donate their old “jalopies” (whether they run or not) and...more

Deductible Charitable Contributions Can Be Made Through An Agent

Most taxpayers making charitable contributions will transfer their own funds or property to the charitable recipient. What happens if another person or entity makes the actual transfer to the charitable recipient?...more

Construction Is Complete On Much Of The Repair Regulations

On September 13, 2013, the IRS and Treasury Department released final regulations regarding the deduction and capitalization of expenditures related to tangible property. Rules were also released regarding accounting for and...more

Legal Alert: An Ode to the Actuaries: Tax Court Concludes that Acuity’s Loss Reserves Were “Fair and Reasonable”

On September 4, the United States Tax Court issued its opinion in Acuity v. Commissioner, T.C. Memo. 2013-209. In brief, the court concluded that Acuity’s reserves for unpaid losses and loss adjustment expenses for 2006, as...more

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