The Eleventh Circuit upheld a deficiency notice of more than $5 million against a taxpayer who reported adjusted gross income of $22,921 and taxable income of $13,221 on his late-filed 2006 return.
News
IRS Announces Two-Year FATCA Enforcement Transition Period
Foreign financial institutions that make a good-faith effort to comply with the requirements of FATCA will benefit from lighter enforcement during 2014 and 2015.
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).
“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.
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.
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.
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.
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.
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.
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.
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).
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.
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).
Trust Materially Participated in Real Estate Business
The Tax Court held that a trust materially participated in its rental real estate business and therefore could deduct the losses it incurred in conducting those activities as losses from nonpassive activities.
Final Rules Issued on Employment Tax Responsibilities of Designated Payer Agents
Final regulations contain rules on the liability for employment taxes when an employer designates an agent under a “service agreement” to pay its employees and to satisfy its employment tax obligations instead of following normal IRS procedures to designate an agent.
Abuse Victims Who File Separate Returns Are Eligible for Premium Tax Credit
Victims of domestic violence who are afraid or unable to contact their spouse to file a joint return may be able to claim the Sec. 36B premium tax credit using procedures announced by the IRS.
Gambler’s Luck Turns in Second Trip to Tax Court
A taxpayer who consistently lost money playing the slots at two casinos in California was found not to have an actual and honest profit objective and could not deduct her gambling losses on Schedule C.
Supreme Court Rules Severance Payments Are Subject to FICA
The Supreme Court held in an 8–0 decision that severance payments to terminated employees are taxable wages for FICA tax purposes.
New Guidance Clarifies Tax Treatment of Bitcoin and Other Virtual Currencies
The IRS issued its first guidance on the tax rules that apply to virtual currencies, in the form of 16 questions and answers.
IRS Clarifies: Electronic Signatures Permitted for Form 8879
The IRS updated the online version of Publication 1345, Handbook for Authorized IRS e-File Providers of Individual Income Tax Returns, to clarify that electronic signatures are permitted for Form 8879 as well as Form 8878.
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.
