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TOPICS / INDIVIDUALS

Long-awaited guidance provided for amortization of R&E expenditures

The IRS says taxpayers and tax professionals can rely on interim guidance under Sec. 174 for the amortization of research and experimental expenditures released on Friday in Notice 2023-63 until it issues proposed regulations based on the guidance, effective for tax years beginning in 2022.

Bad debt deductions from intrafamily advances

Loans within families can give rise to a loss deduction if not repaid, but this requires establishing, maintaining, and documenting a bona fide debtor-creditor relationship.

Taxpayer marital status and the QBI deduction

This article provides an analysis in four scenarios of whether the QBI deduction will cause a marriage penalty or bonus and discusses whether the existence of a marriage penalty or bonus affects couples’ decision to marry.

Standard mileage rate increased July 1

Effective for miles traveled on or after July 1, 2022, the standard mileage rate for purposes of deductible business expenses is 62.5 cents per mile, an increase of 4 cents from the 58.5 cents per mile applicable to travel between Jan. 1, 2022, and June 30, 2022.

Paying for personal guaranties of company debts

A partner providing a personal guaranty may be entitled to an increase in the basis of his or her partnership interest by virtue of guaranteeing the partnership’s debt.

Microcaptive insurance arrangements after CIC Services

A federal district court recently held that Notice 2016-66, which classifies certain microcaptive insurance arrangements as transactions of interest that are reportable transactions under Regs. Sec. 1.6011-4, is invalid under the Administrative Procedure Act. This article discusses the ramifications of the decision for taxpayers engaging in microcaptive insurance transactions and possible responses to the decision by the IRS.

Current developments in taxation of individuals

This semiannual update covers recent federal tax developments involving individuals, highlighting noteworthy IRS guidance and decisions of the Tax Court and other courts, as well as tax changes made by legislation.

Minimizing a hobby loss issue by electing S status

To avoid the hobby
loss rules, with
their limitation on
deductible expenses,
an activity must be
engaged in for profit;
electing S status
can help a taxpayer
establish profit
motive.