April 2014

April 30, 2014

Tenth Circuit Throws Out IRS Summonses

In a decision that creates a split from five other circuit courts, the Tenth Circuit Court of Appeals quashed IRS summonses that were issued after the 23-day period required under Sec. 7609(a)(1).

April 25, 2014

“Killer B” Anti-Abuse Regulations Are on the Way

The IRS announced that it will amend the existing regulations on cross-border reverse triangular reorganizations, popularly known as “Killer B” transactions.

April 23, 2014

IRS Issues 2015 Inflation Adjustments for HSAs

The IRS issued the calendar year 2015 inflation-adjusted figures for the annual contribution limits for HSAs and the minimum deductible amounts and maximum out-of-pocket expense amounts for high-deductible health plans.

April 16, 2014

Taxpayers Must Reveal Tax Shelter Opinion Letters Despite Attorney-Client Privilege

By attempting to establish good-faith and state-of-mind defenses, taxpayers put their legal knowledge and understanding into contention, and therefore they waived attorney-client privilege.

April 14, 2014

Foreign Housing Expense Limitations Issued for 2014

On Monday, the IRS provided its annual list of inflation-adjusted limitations on foreign housing expenses for 2014.

April 10, 2014

Horse Breeder Materially Participated

The Tax Court held that a taxpayer materially participated in his horse-breeding activity for 2002 through 2004 and therefore was not barred from deducting his losses as passive activity losses under Sec. 469.

April 7, 2014

Guidance Issued on Application of Windsor to Retirement Plans

Administrators of qualified retirement plans must recognize the same-sex spouses of legally married participants as of June 26, 2013, under guidance issued by the IRS.

April 4, 2014

Taxpayers Can Claim Charitable Contributions for Typhoon Relief on 2013 Returns

The IRS announced procedures under the Philippines Charitable Giving Assistance Act, which allows taxpayers to take deductions for cash contributions to qualified charities for the relief of victims of Typhoon Haiyan on their returns for the 2013 tax year.

April 3, 2014

Plan Administrators Can Assume Certain Rollovers Are Valid

The IRS ruled that a plan administrator for a plan that is qualified under Sec. 401(a) may reasonably conclude in the situations described in the ruling that a potential rollover contribution is valid under Regs. Sec. 1.401(a)(31)-1, Q&A-14(b)(2).

April 1, 2014

AICPA Recommends Changes to Net Investment Income Tax Rules

The AICPA submitted a comment letter to the IRS recommending a number of changes to the Sec. 1411 regulations on the application of the net investment income tax to charitable remainder trusts when final regulations are issued.

April 1, 2014

How to Calculate Employer Health Care Responsibilities

To determine whether a business is subject to the employer mandate penalty under the Patient Protection and Affordable Care Act, the business must determine the number of its full-time employees, which includes its full-time equivalent employees (FTEs).