Determining qualified dividend income from foreign corporations may require examining tax treaties and U.S. statutory exclusions, as well as studying the potential effect of pending regulations.
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TOPICS
Individuals
Erroneous refund of interest does not support innocent-spouse relief
Taxpayer not entitled to equitable innocent-spouse relief for erroneous refund of interest.
IRS increases special per diem rate for business travel
The special per diem rates that a taxpayer uses in travel and business expenses will be higher starting Oct. 1, as provided by the IRS.
Proposed regs. would exclude tribal general welfare benefits from income
The first proposed regulations under Sec. 139E set out the requirements for excluding Indian tribal general welfare benefits from income.
Like-kind exchanges of real estate: Back to basics
This article discusses the requirements for gain deferral under Sec. 1031 and highlights frequently encountered issues.
Current developments in taxation of individuals
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending April 2024.
Bidding farewell to US citizenship: Understanding the exit tax
Potentially costly and far-reaching tax liabilities of covered expatriates should give individuals pause before renouncing U.S. citizenship or permanent resident status.
Fact sheet addresses taxability of crowdfunding distributions
The IRS said that crowdfunding distributions may be included in the gross income of the person receiving them, depending on the facts and circumstances of the distributions.
Bitcoin ETFs: The known and unknown
As bitcoin exchange-traded funds enter the investment marketplace, tax advisers and their clients should note key considerations for digital assets.
Academic research sheds light on important tax matters
Recent academic journal articles of potential interest to tax practitioners investigated companies’ tax-avoidance behavior, knowledge sharing between accounting firms’ audit and tax personnel, the TCJA’s effects on US corporations’ debt structure and effective tax rates, and how cryptoasset investors respond to tax-compliance scrutiny.
Sec. 163(j) planning considerations
Businesses can explore several options to mitigate the interest deduction limitation under the Tax Cuts and Jobs Act.
Converting a rental or vacation home into a primary residence
Individuals relocating to another dwelling they own may face tax issues including periods of nonqualified use and, for previous rental units, depreciation recapture.
Avoiding passive loss limitations on rental real estate losses
Strategies for using the $25,000 offset for rental real estate losses can include keeping income within its phaseout range and contributing the loss activity to a closely held C corporation.
Deficiency notice invalid because IRS cannot prove last known address
The Tax Court held the Service did not show it followed its regulations and procedures to update a taxpayer’s address to which it sent the notice.
IRS steps up enforcement of the individual expatriation tax
The Sec. 877A exit tax applies to specified expatriating U.S. citizens and long-term residents on gains from a deemed sale of assets. Expatriates’ numbers have risen, and the IRS is emphasizing compliance.
Petition timely filed as regulations held invalid
Regulations governing the time for filing a Tax Court petition during a federally declared disaster are invalid, and the taxpayers met Sec. 7508A(d)’s mandatory postponement provision, the court holds.
Third Circuit rejects IRS’s mootness claims
The IRS’s setoffs of estimated payments against the taxpayer’s deficiencies were invalid, the court finds, making the taxpayer’s lawsuit a live case or controversy.
Foreign trust transactions and large gifts addressed in proposed regs.
The proposed regulations implement Secs. 643(i), 679, 6039F, 6048, and 6677, which were added or modified to prevent efforts by U.S. taxpayers to use foreign trusts and offshore arrangements to avoid U.S. taxes.
Final regs. issued for new, previously owned clean vehicle credits
The final regulations, which the IRS issued Friday, also provide rules regarding the critical mineral and battery component requirements for the new clean vehicle credit, and they add a new test for mineral content.
Amendment to Sec. 6501 not retroactive
Because his tax year preceded the effective date of a special limitation period that was not retroactive, a taxpayer could be assessed excise taxes on $25 million in excessive IRA contributions, the Tax Court held.
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.
