The AICPA and IRS have corresponded regarding the AICPA’s concerns about the Service’s program to request the accounting software files of certain small business taxpayers under examination
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TOPICS
IRS Practice & Procedure
Supreme Court Strengthens Power of Interpretive Treasury Regs.
In the Mayo decision, the Supreme Court determined the level of deference owed to an interpretive Treasury regulation under which persons who work 40 hours or more per week are treated as employees rather than students for FICA purposes.
IRS Announces Changes to Lien Process
The IRS has announced a set of new policies designed to help taxpayers pay their back taxes and avoid liens. It also announced that it is making it easier for taxpayers to enter into an installment agreement and is expanding its streamlined offer in compromise program.
IRS Announces Tax-Exempt Bond Voluntary Closing Agreement Program
The IRS has announced a program to provide relief from debt extinguishment for certain issuers that purchase and hold their own tax-exempt bonds.
Violation of Public Policy and the Denial of Deductions
Recent events have drawn attention to the disallowance of deductions where allowing the deductions would violate public policy. This article discusses the disallowance of deductions under Sec. 162 and Sec. 165 for public policy reasons.
Schedule UTP: IRS Mandates Disclosure of Uncertain Tax Positions
This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
Day-Trading Losses Are Dissipation of Assets
The Tax Court held that a taxpayer’s losses from a period of day-trading activity constituted a dissipation of assets that the IRS could take into account in determining whether to accept the taxpayer’s offer in compromise.
Final Regs. Issued on Disclosing Return Information to Whistleblowers
The IRS released final regulations regarding the disclosure of return information by the Treasury Department in connection with written contracts among the IRS, whistleblowers, and, if applicable, their legal representatives.
Regulation of Tax Return Preparers
To improve the oversight of tax preparation by paid tax preparers, the IRS has established a registration, examination, and continuing education regime for paid tax preparers. This article discusses the general requirements under the regime and the specific rules and exceptions to the rules for CPAs.
Extended Period for Receiving Authorization to Disclose Return Information Proposed
The IRS issued a proposed regulation that would officially extend from 60 to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees because some financial institutions have had difficulty obtaining and submitting written authorizations within the current 60-day limit.
IRS Extends, Modifies Program Allowing Truncated Social Security Numbers on Information Returns
The IRS announced that it is extending and modifying a pilot program designed to deter identity theft that allows filers of certain paper information returns to truncate the payee’s Social Security number on the payee statement.
President Signs Repeal of Expanded 1099 Requirements
The president signed into law repeal of both the expanded Form 1099 information reporting requirements mandated by last year’s health care legislation and also the 1099 reporting requirements imposed on taxpayers who receive rental income enacted as part of last year’s Small Business Jobs Act.
AICPA’s Call for AMT Repeal, Simplification Strikes Chord with Lawmakers
Annette Nellen, chair of the AICPA Individual Income Taxation Technical Resource Panel, pleased some members of Congress when she repeated the AICPA’s support for repeal of the alternative minimum tax (AMT) in testimony before the House Ways and Means Committee on April 13.
Federal Budget Deal Avoids Tax Season Disruptions
White House and congressional negotiators reached an agreement on funding the federal government ahead of a midnight April 8 deadline and averted a shutdown of all nonessential government functions.
IRS Prepared to Process Returns If Government Shuts Down
IRS Commissioner Doug Shulman answered questions at the National Press Club regarding the IRS’ preparations for a possible shutdown of the federal government, which could happen Friday.
Senate Approves 1099 Repeal, Sends Bill to President
The Senate April 5 passed legislation to repeal both the expanded Form 1099 information-reporting requirements mandated by last year’s health care legislation and also new 1099 reporting requirements imposed on taxpayers who receive rental income.
Final Regulations Issued on Validity, Priority of Federal Tax Liens
The IRS published final regulations that govern the validity and priority of federal tax liens under Sec. 6323.
IRS Refocuses Large Business Operations, Highlights International and Global High-Wealth Cases
This item highlights IRS efforts to refocus the work of its former Large and Midsize Business (LMSB) Division, now known as the Large Business and International (LB&I) Division, in an effort to strengthen international compliance.
The Need for Increased Due Diligence in Filing Extensions
This item reviews the requirements for filing for extensions, estimating tax liability, and paying all due tax liabilities.
90-Day Letter Does Not Start If Mail Is Undeliverable, Rules One Court
The Fifth Circuit held that a statutory notice that was mailed to an incorrect address and returned by the Postal Service was null and void
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
