This article discusses the unique tax issues facing creators of intellectual property, particularly federal income tax treatment for individual taxpayers.
Gains & Losses
The IRS issued final and proposed regulations giving guidance on the application and computation of the 3.8% net investment income tax imposed by Sec. 1411.
The D.C. Circuit held that nonresident aliens should measure their gambling gains and losses under the “per-session” approach, the same method that U.S. citizens follow, instead of a "per-bet" approach.
The existence of convertible debt, incentive stock options, warrants, and preferred stock, along with the need for additional capital, creates opportunities for tech companies to issue additional qualified small business stock in 2013.
In August, the IRS released a draft dual-purpose form that will be used by individuals and trusts and estates to compute and report the new 3.8% net investment income tax.
A decision by the D.C. Circuit puts nonresident aliens’ gambling gains on a closer footing to those of U.S. residents.
A portion of the gain from the sale of a principal residence can be excluded when the taxpayer fails to meet the requirements for full exclusion of gain when the primary reason for selling or exchanging the principal residence was a change in place of employment, health, or unforeseen circumstances.
This article covers recent developments in individual taxation. The items are arranged in Code section order.
The AICPA, in a letter from Jeffrey Porter, chair of the AICPA Tax Executive Committee, submitted comments to the IRS, recommending many changes to the proposed regulations on the new net investment income tax.
The IRS released a draft of Form 8960, a new dual-purpose form that will be used by individuals and trusts and estates to compute the new 3.8% net investment income tax.
The AICPA submitted comments to the IRS recommending many changes to the proposed regulations on the new net investment income tax.
Sec. 1202 provides an opportunity for investors to make investments that could qualify for a full federal income tax exemption on a subsequent sale.
The proposed regulations under Sec. 1411 do not provide a definition of “trade or business” for taxpayers engaged in rental real estate activities and thus potentially subject to the tax on net investment income on income from these activities.
Final regulations implementing the basis reporting requirements under Sec. 6045(g) phase in the reporting requirements for debt instruments and transfer reporting.
This item discusses provisions addressed in the 3.8% Medicare tax proposed regulations pertaining to the definition of business income as net investment income, grouping of activities, and treatment of the sale of S corporation stock and partnership interests.
Thee IRS issued proposed regulations for the net investment income tax under Sec. 1411 that went into effect on Jan. 1, 2013. At the same time, the IRS released a list of frequently asked questions concerning the net investment income tax.
The Tax Court held the IRS could not reclassify the taxpayer’s income from the rental of cellphone towers and the land they were situated on to his wholly owned S corporation as nonpassive income under the self-rental rule.
Activity grouping is an often overlooked or misused component of tax strategy and compliance, and with the issuance of Rev. Proc. 2010-13, the importance of getting it right has increased.
The IRS released proposed regulations governing the 3.8% net investment income tax imposed under Sec. 1411.
The IRS issued proposed regulations to update the rules that apply to U.S. taxpayers that fail to file gain recognition agreements when they transfer certain property to foreign corporations in nonrecognition transactions