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.
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TOPICS
Individuals
AICPA recommends changing cryptoasset question
In a comment letter to the IRS, the AICPA recommended changes and clarifications regarding the tax treatment of cryptoassets or “virtual currency.”
Guidance on clean vehicle tax credit
The IRS explained the new requirement that a car’s or truck’s final assembly occurred in North America to qualify for the tax credit on the purchase of clean-running vehicles.
Congress enacts tax and climate bill
With Senate amendments approved by the House on Friday, the budget reconciliation bill now known as the Inflation Reduction Act will go to the president for his signature.
Key tax provisions in the Senate reconciliation bill
The Inflation Reduction Act passed by the Senate on Sunday includes many tax items, some designed to raise revenue and others to promote various clean energy initiatives.
IRS may enforce lien to pay off deceased life partner’s tax debts
Property of a taxpayer may be used to satisfy the tax liabilities of a life partner.
Tax consequences of real property foreclosures
Real property foreclosures can produce various tax consequences depending on whether the debt is recourse or nonrecourse.
IRS litigators not bound by innocent-spouse determination
The IRS Cincinnati Centralized Innocent Spouse Operation’s opinion that a taxpayer was entitled to relief was not binding on the Office of Chief Counsel as a ‘final determination’ of liability.
Foreign earned income exclusion: Pandemic-related relief
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
Regs. proposed for present value of estate deductions
Administrative expenses and claims against estates allowable under Sec. 2053 beyond a three-year grace period would be discounted for current deduction, under proposed rules issued by the IRS.
IRS extends e-filing to more 1040-series amended returns
Nonresident alien amended returns and those for Puerto Rico residents are added; superseding returns can be designated.
Midyear IRS mileage rate increase follows precedent, recent pleas
Last week’s bump was the third midyear increase in the past 14 years, and it came after members of Congress wrote to the IRS about rising fuel prices.
Standard mileage rate to increase for last half of 2022
Acknowledging recent sharp increases in gasoline prices, the IRS announced a rare midyear increase in the standard mileage rate, starting July 1.
IRS warns of impostors in ‘Dirty Dozen’
The IRS’s annual series continues with caveats about fake communications intended to bilk taxpayers out of their tax and financial information.
‘OIC mills’ and ‘ghost’ preparers in ‘Dirty Dozen’
Sketchy operations target tax debtors for offers in compromise, and preparers who remain anonymous on returns generally have something to hide, the IRS says in its ongoing series.
More ‘Dirty Dozen’: Tax refund theft and fake charity appeals
The IRS continued its annual series, highlighting threats to ordinary taxpayers from would-be thieves.
Abusive CRATs and Maltese IRAs among ‘Dirty Dozen’ tax scams
The first installment of the Internal Revenue Service’s annual feature focuses on four abusive transactions and arrangements.
‘Swag bags’ are back: Influencers and noncash compensation
This item discusses whether and when ‘freebies’ or discounts result in taxable income to the influencer and possible limitations on deductions for the related expenses.
Dispute remains over whether couple sold house due to poor health
Taxpayer’s health may have been the reason for sale of personal residence, but the issue may not be material to whether taxpayers are entitled to an exclusion of gain on the sale.
IRS mostly correct on recovery rebate credits, TIGTA says
The IRS administered the recovery rebate credit correctly for all but 0.7% of returns in the 2021 filing season, the Treasury Inspector General for Tax Administration found.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
