Latest Posts › IRS

Share:

Final Section 162(f) Regulations Set Forth Deductibility Rules for Payments Involving Government Investigations

Background - Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more

Taxpayer Developer’s $4M Land Donation Upheld in Quid Pro Quo Contribution/Appraisal Compliance Case

An individual donating land to a municipality simultaneously when seeking to obtain development approvals from that same municipality often encounters the issue of whether the contribution lacked charitable intent and if the...more

11/3/2020  /  Donations , Easements , IRS , Quid Pro Quo

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

CARES Act And Recent IRS Guidance Provide Significant Benefit For Real Estate Businesses And Investors

The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as well as IRS guidance released in the last few days, aim to provide real estate businesses, among others, with decreases or delays in...more

May 15 Deadline Approaching for New Excise Tax Triggered Even When Tax-Exempt Organizations Pay No Compensation

Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more

Addition of UBTI Siloing Rules Creates New Challenges for Tax-Exempt Organizations - Tax Update Volume 2019, Issue 2

Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more

Tax Update, Volume 2017, Issue 2

THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

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

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

The IRS and Courts Weigh in on the Deductibility of Fines and Penalties - Tax Update, Volume 2016, Issue 3

Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty. Originally...more

Final Noncompensatory Partnership Options Regulations Could Affect the Tax Treatment of Penny Warrants and Other Arrangements

Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more

In Frank Aragona Trust, Tax Court Holds that Trustees’ Activities as Employees Count for Purposes of Material Participation Under...

The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more

Challenges To Deducting Settlement Payments Under The False Claims Act: Fresenius Sheds Light On The Burden

Whether a business may deduct litigation settlement payments can have a substantial real dollar impact on the business. In the midst of combating potential litigation, companies rarely first focus on the potential tax impact...more

Federal Appeals Court Holds That Supplemental Unemployment Compensation Benefits Are Not ‘Wages’ Subject To FICA Taxation,...

In an important recent decision, United States v. Quality Stores, Inc., et al., Case No. 01-1563, 2012 U.S. App. LEXIS 18820 (6th Cir. Sept. 7, 2012), the U.S. Court of Appeals for the Sixth Circuit held that supplemental...more

Changes In The IRS Independent Contractor Classification Program

In September 2011 the Internal Revenue Service (IRS) announced a new voluntary relief program for worker status termed the voluntary classification settlement program (VCSP). Announcement 2011-64, 2011-41, I.R.B. 503. On...more

15 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide