Procedures for obtaining equitable relief from a joint tax liability under Secs. 6015(f) and 66(c) were recently modified.
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TOPICS
Individuals
Impact of Sec. 1411 on S Corporations and Their Shareholders
One of the more significant changes to the tax landscape in recent years is the new 3.8% tax on net investment income under Sec. 1411. This tax, which was further clarified in recently finalized regulations, will affect many entities and taxpayers including S corporations and their shareholders. This discussion outlines noteworthy aspects of these rules pertaining to S corporations and their owners.
Ellis, the Case of a Misdirected IRA
Potential entrepreneurs need to be aware of the tax complexities of using retirement funds as startup capital.
Director Fees May Be Subject to Self-Employment Tax
The Tax Court in Blodgett, T.C. Memo. 2012-298, provided useful information to determine corporate directors’ income classification when the initial answer may be unclear.
Individual Taxation: Digest of Recent Developments: Part II
This is the second of a two-part article covering recent developments affecting taxation of individuals, including regulations, cases, and IRS guidance.
Americans Living Abroad and the Net Investment Income Tax
This article describes how the net investment income tax may affect Americans living abroad.
President Orders New Retirement Savings Vehicle
President Barack Obama in his annual State of the Union speech announced a new retirement savings account to be made available to employees through their employers.
Transition Relief Offered on Minimum Essential Coverage and Shared-Responsibility Penalty
Proposed regulations issued by the IRS answer a number of questions regarding the Sec. 5000A individual mandate under 2010’s health care reform legislation.
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.
IRA Rollover Guidance Issued: IRS Will Follow the Tax Court
The IRS announced it will follow the recent decision in Bobrow, meaning no matter how many IRAs a taxpayer has, the taxpayer is limited to one IRA rollover per year.
Earnout Restriction Causes Substantial Risk of Forfeiture
The Tax Court held that sections of a restricted stock agreement and an employment agreement read together constituted an earnout restriction that might create a substantial risk of forfeiture for stock transferred to an employee.
Condemnation of Pipeline Easements: The Landowner’s Perspective
This article examines income tax issues that commonly arise in connection with the conveyance of pipeline easements and surface sites and identifies planning opportunities.
Guidance Issued on Cafeteria Plan, HSA, FSA Issues for Same-Sex Married Couples
Recent IRS guidance deals with elections and reimbursements for cafeteria plans, health savings accounts, and health, adoption, and dependent care flexible spending arrangements for same-sex married couples.
Individual Taxation: Digest of Recent Developments: Part I
This article is Part I of a two-part article covering recent developments affecting taxation of individuals, including regulations, cases, and IRS guidance.
2014 Car, Truck Depreciation Limits Issued
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
Final Substantial-Risk-of-Forfeiture Rules Are Released
The IRS finalized regulations that clarify when a substantial risk of forfeiture exists on the transfer of stock to an employee that is treated as compensation under Sec. 83 (T.D. 9659).
“Dirty Dozen” Tax Scam List Now Includes Telephone Scams
Identity theft and telephone scams top this year’s list of the “Dirty Dozen” fraudulent tax schemes released by the IRS.
2014 Standard Mileage Rates Go Down
The optional standard mileage rates for use of a vehicle have gone down by one-half cent per mile for 2014.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
