The Corporate Transparency Act (CTA) and its reporting requirements has now gone live as of the first of this year and applies to nearly all existing and future entities (corporations, partnership and limited liability...more
Starting January 1, 2024, many new and existing U.S. and foreign entities will be required to file reports with the Financial Crimes Enforcement Network (“FinCEN”), a division of the U.S. Treasury. ...more
Treasury issued Notice 2020-51 today on CARES Act § 2203, the 2020 Waiver of Required Minimum Distributions (“RMDs”) that contained important (and in part some surprising) guidance. Here are some of these important points....more
The Coronavirus Aid, Relief, and Economic Security, or “CARES Act” - the third emergency bill that Congress has passed in response to the novel coronavirus (COVID-19) pandemic - was signed into law on Friday, March 27, 2020....more
While the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) has not yet been enacted, there are many who anticipate that it will be enacted by year end, primarily because it passed the House...more
The Tax Cuts and Jobs Act of 2017 (TCJA) eliminated all miscellaneous itemized deductions that are subject to the 2% floor, capped state and local taxes deduction at $10,000, and doubled the standard deduction for single...more
The Tax Cuts and Jobs Act of 2017 (TCJA) eliminated all miscellaneous itemized deductions that are subject to the 2% floor, capped state and local taxes deduction at $10,000, and doubled the standard deduction for single...more
Trusts and Estates practitioners often focus solely on the Tax Code found in Title 26 of the United States Code and ignore other parts of the United States Code (U.S.C.). However, it is a mistake to do so as Marci McNicol...more
Not only is strict adherence to the structure set out in prior favorable rulings best, it is essential when it comes to obtaining a favorable ING ruling. The provisions in the trust document need to carve a very fine line...more
Ozimkoski v. Commissioner,
T.C. Memo. 2016-228 (December 19, 2016) -
Mrs. Ozimkoski (Suzanne) represented herself in this Tax Court case. She may also have represented herself in the final days of settling the...more
IRS Notice 2017-12 -
The Service issued FAQs in June of 2015 to let practitioners know that they were no longer routinely issuing closing letters. The Service instructed practitioners that they would now have to request...more
The recent issuance of Rev. Proc. 2016-49, which modifies and supersedes Rev. Proc. 2001-38, now puts the taxpayer in the driver’s seat. Recall that in Rev. Proc. 2001-38, the Service was providing relief for the surviving...more
Dorrance v. U.S., 2015 WL 8241954 (9th Cir. 2015) -
This case is the latest in the cases involving tax impact of the sale of stock received by a policy holder from a mutual life insurance company on demutualization, and...more
When the taxpayer in PLR 201547010 decided to invest his IRA assets in a partnership, he forgot to check whether his IRA provider was able to hold an interest in a partnership as an investment in the IRAs for which it served...more