In written and oral testimony, Jeffrey Porter, CPA, addressed the impact of tax uncertainty in several areas and made recommendations on behalf of the AICPA for alleviating some of that uncertainty.
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Publicly Traded Property Defined for Determining Issue Price of Debt Instruments
The IRS issued final regulations defining “publicly traded property” to determine the issue price of a debt instrument.
Use of Wrong Delivery Service Results in Dismissal of Tax Court Petition
Taxpayers who chose the wrong type of FedEx delivery service did not get the benefit of the timely mailing/timely filing rule and as a result had their petition dismissed.
Guidance Issued on Employee Expense Reimbursement Arrangements
The IRS issued guidance on situations in which employers recharacterize wages as nontaxable reimbursements and whether they met the requirements to be treated as paid under an accountable plan.
Employee Health Insurance Safe Harbors Expanded
The IRS expanded and revised optional safe harbors on which applicable large employers may rely in complying with requirements starting in 2014 to provide health insurance coverage to their full-time employees.
Automatic Accounting Method Changes to Be Allowed in Corporate Reorganizations
The IRS announced a change in its policy on automatic accounting method changes in corporate reorganizations.
Taxpayer Advocate Service Changes Criteria for Accepting Cases
The Taxpayer Advocate Service changed its criteria for accepting individual taxpayer cases for assistance.
Proposed Regs. Issued on Allocating Sec. 263A Costs Under Simplified Methods
The IRS issued proposed regulations that affect taxpayers who produce or resell property and allocate costs under the simplified production method or simplified resale method.
Statutory Definition of Notional Principal Contract Further Extended Through 2013
The IRS announced that it was further extending the effective date until 2014 for proposed regulations issued under Sec. 871(m).
IRS Launches Redesigned Website; Temporarily Takes Down Some Services
A redesigned IRS.gov website went live on Aug. 30; however, the IRS also announced that it is taking down several of its online services during the Labor Day weekend.
IRS Changes Stance on Application of Sec. 6662 Penalty to Frozen Refundable Credits
The IRS announced that it would no longer impose a penalty under Sec. 6662 for a substantial understatement of tax when a taxpayer claims a refundable tax credit he or she is not entitled to, but the IRS does not pay the refund or approve the credit.
AICPA Provides Guidance on FSA Certification Letters
Tthe AICPA has worked with the FSA to create a certification letter CPAs can use when their clients are asked to certify income and is providing its members with sample engagement and disclosure letters to be used in connection with providing a certification letter for clients.
Federal Law Preempts Alabama Statute Denying Tax Deduction for Illegal Alien Employees
The Eleventh Circuit held that an Alabama law that disallowed an employer a state tax deduction for wages and compensation paid to an alien unauthorized to work in the United States was preempted by federal immigration law.
IRS Chief Counsel’s Office Issues Advice on Identity Theft Returns
The IRS Office of Chief Counsel explained what the IRS can do when a return is filed by an identity thief in order to generate a fraudulent refund and the IRS has issued a statutory notice of deficiency based on that fraudulent return.
IRS Announces the End of Tiered Issues
Effective Aug. 17, 2012, the IRS will no longer use the tiered management process to set examination priorities and address important issues in the Large Business & International division.
Draft Form 706 Provides Check Box to Not Elect Portability
Draft Form 706 addresses portability of a deceased spouse’s unused estate and gift tax exclusion amount and provides a check box for the executor to opt out of electing portability of the unused portion.
Corporation Cannot Deduct California Business Privilege Tax in Year Paid
An accrual-basis taxpayer could not deduct the California business privilege tax in the year it was paid, even though California treated the tax as being incurred in that year.
Removal of Two-Year Limit on Innocent Spouse Claims Does Not Revive Taxpayer’s Case
A federal court dismissed a taxpayer’s claim that she was entitled to innocent spouse relief under Notice 2011-70, which announced the removal of the two-year limitation period for claims for equitable innocent spouse relief under Sec. 6015(f).
TIGTA: IRS Encourages Employees to Ignore ITIN Fraud
TIGTA confirmed allegations from IRS employees that their supervisors were urging them to ignore potential fraud in a program that reviews and verifies applications for ITINs.
Fraud Convicts Cannot Argue in Tax Court That Payments Did Not Result From Fraud
Taxpayers who were convicted of fraud are precluded from later arguing that payments they received were not the result of fraud, the Tax Court held in two related cases
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
