The IRS published regulations addressing certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions.
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TOPICS
Individuals
IRS Clarifies When Debt Instruments Are Publicly Traded
The IRS issued final regulations clarifying the circumstances in which property is traded on an established market (i.e., publicly traded) for purposes of determining the issue price of a debt instrument.
Mandatory Language for Consents to Disclose, Use Taxpayer Information Modified
The IRS has provided guidance to tax return preparers about the format and content of taxpayer consents to disclose and consents to use tax return information and modified the mandatory language required on each taxpayer consent.
IRS Issues Proposed Regs. on 3.8% Net Investment Income Tax
The IRS released proposed regulations governing the 3.8% net investment income tax imposed under Sec. 1411.
Guidance Issued on Additional Medicare Tax
The IRS issued proposed regulations concerning the 0.9% Medicare surtax, which takes effect next year.
Who Can or Must File a Form 1099-C?
With taxpayers and businesses defaulting on credit and loans, tax advisers may consider whether their clients should issue a Form 1099-C for a bad debt.
Prop. Regs. Provide Guidance on Meals and Entertainment Expenditures
Proposed regulations clarify the definition of a reimbursement or other expense allowance arrangement and provide guidance on the applicability of the Sec. 274(e)(3) exception under various circumstances including employer/employee, two-party, and multiparty arrangements.
Contemporaneous Documentation of Charitable Contributions
Earlier this year, the Tax Court highlighted how an apparently slight oversight in documentation can upend the interdependent relationship between donee and donor.
Per Diem Rate Updates for 2012–13
The IRS has issued its annual update of special per diem rates for use in substantiating certain business expenses taxpayers incur when traveling away from home.
Crop Insurance Proceeds: Appropriate Tax Planning Strategies
The severe drought experienced by much of the United States this year, especially in agricultural regions, is expected to produce a record number of crop insurance claims.
Individual Tax Update
This article covers recent developments affecting individual taxation.
Receipt of Form 1099-C May Not Signal Taxable COD Income
It is up to the taxpayer and his or her advisers to correctly identify the appropriate year in which to recognize COD income based on the date it is clear the debt will not be repaid.
Is the Sale of Real Property Ordinary Income or Capital Gain?
Determining whether a real estate sale produces ordinary income or capital gain is difficult and is potentially an issue that can cause a taxpayer to be liable for significantly higher taxes.
Inflation Adjustments for 2013
The IRS released its annual revenue procedure making inflation adjustments to the gift tax annual exclusion and other items for tax years beginning in 2013.
Measuring Insolvency Under Sec. 108
While determining if a taxpayer is bankrupt is straightforward, determining whether a taxpayer is insolvent can be tricky.
Advising Clients Amid Constitutional Challenges to the Defense of Marriage Act
Recent court decisions provide an opportunity and responsibility for tax practitioners to assist their clients in same-sex marriages with protecting their rights to federal and state tax refunds as well as providing additional advice regarding income and gift and estate tax planning in light of DOMA’s uncertain future.
Income from Partnership Is Self-Employment Income Where Taxpayer Chose Not to Be a Partner
The Eleventh Circuit held that payments a taxpayer received from a nursing home business were taxable self-employment income despite the taxpayer’s convoluted attempts to characterize them as partnership distributions.
Standard Mileage Rates Go Up a Penny in 2013
Optional standard mileage rates for use of a vehicle will go up by 1 cent per mile for 2013, the IRS announced.
Hurricane Sandy Victims Can Take Hardship Distributions, Loans, From Retirement Plans
The IRS will allow taxpayers who have been adversely affected by Hurricane Sandy to take hardship distributions or loans from their retirement plans.
Leave-Based Donation Programs Allowed for Hurricane Sandy Relief
In response to the extraordinary damage caused by Hurricane Sandy and the extreme need for relief, the IRS has released guidance for employers who are considering adopting leave-based donation programs to aid the storm’s victims.
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.
