Establishing an IRA in a child’s name can be an effective planning technique for a child with earned income.
Individuals
Taxing the Transfer of Debts Between Debtors and Creditors
Assumptions and other transfers of debt between corporations and shareholders or between partnerships and partners can often be tax free as part of a contribution, distribution, reorganization, or liquidation. This article analyzes several types of debt transfers and their potential for recognition of gain or loss and income from cancellation of debt.
Supreme Court Upholds Health Care Law
The Supreme Court declared the mandate requiring U.S. citizens and legal residents to maintain minimum essential health coverage to be a permissible exercise of Congress’s taxing powers under the Constitution.
Sample Text for Sec. 83(b) Election Released by IRS
The IRS released sample language for making the Sec. 83(b) election and examples of the amount of income taxpayers would recognize if they made the election.
IRS Suspends Issuing ITINs Without Original Documentation
The IRS will no longer issue individual taxpayer identification numbers unless the applicants provide original documents, such as passports or birth certificates, or certified copies of those documents from the issuing agencies.
Tips and Service Charges Distinguished in Guidance
The IRS issued question-and-answer guidance for distinguishing between tips and service charges for FICA tax and other purposes.
A Road Map of Tax Consequences of Modifying Debt
As a result of the recession, many borrowers are “underwater” on their loans (the property is worth less than the loan balance). This has led to a substantial increase in debt restructuring activity.
Section 530 Relief for Worker Classification Controversies
This article reviews the common law principles and authoritative guidance available to distinguish when workers are employees and the Section 530 safe-harbor provisions.
No Deduction Allowed for Contribution of Easement
The Tax Court held that a taxpayer was not entitled to a charitable deduction for a contribution of a conservation easement on land subject to a mortgage because the mortgagee’s rights in the land had not been subordinated to the rights of the charitable organization that received the easement.
First Circuit Strikes Down Defense of Marriage Act but Stays Tax Remedies
The First Circuit Court of Appeals declared part of the federal Defense of Marriage Act unconstitutional, upholding a Massachusetts federal district court decision.
Prop. Regs. Clarify Meaning of “Substantial Risk of Forfeiture” Under Sec. 83
The IRS issued proposed regulations that would clarify when a substantial risk of forfeiture exists on the transfer of stock to an employee that is treated as compensation under Sec. 83.
Final Regs. Issued on Health Insurance Premium Tax Credits
The IRS issued final regulations governing the Sec. 36B health insurance premium tax credit enacted by 2010’s health care legislation.
Farm Debtors Must Pay Capital Gain Tax in Full, the Supreme Court Holds
The U.S. Supreme Court ruled that farmers who sold farm assets during a bankruptcy reorganization under Chapter 12 of the Bankruptcy Code were liable for the full amount of the capital gains tax that resulted from the sale
Final Regs. Explain Allocation of Deduction for Prepaid Mortgage Insurance Premiums
The IRS issued final regulations governing the allocation of prepaid mortgage insurance premiums for periods after Dec. 31, 2010.
Terms in OIC Agreement Take Meaning From Code, Court Holds
The Second Circuit held that the terms “refund” and “overpayment” in an OIC agreement are specialized tax terms that take their meaning from the Code and are not given their “plain English” meanings, despite the colloquial tone of the agreement.
Guidance Issued on Interest Exceeding Acquisition and Home Equity Indebtedness Limitations
The IRS recently released guidance for allocating excess mortgage interest expense.
Opportunities for Incorporating International Tax Law Into All Levels of the Tax Curriculum
Considering the global nature of today’s businesses, covering international topics is necessary at all levels of the business curriculum.
2012 Automobile Depreciation Limits
The IRS issued the 2012 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F (Rev. Proc. 2012-23).
Qualified Residence Interest Limits Apply on a Per Residence Basis
The Tax Court held that, for purposes of calculating qualified residence interest, the Sec. 163(h)(3) limits on the amount of indebtedness that qualifies as acquisition or home equity indebtedness do not apply separately to co-owners of property who are not married.
HSA Inflation Adjustments Issued for 2013
The IRS issued the inflation-adjusted figures for the annual contribution limitation for HSAs and the minimum deductible amounts and maximum out-of-pocket expense amounts for high-deductible health plans for calendar year 2013.
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.
