The IRS issued final regulations regarding the new information reporting requirement under Sec. 6050W for payment card and third-party network transactions.
IRS Practice & Procedure
IRS Will Stop Providing Debt Indicators; Exploring Ways for Taxpayers to Use Refunds to Pay Preparers
The IRS announced that it will stop providing “debt indicators” to tax preparers and associated financial institutions.
IRS Changes Name of LMSB Division, Expands Focus
The IRS is reorganizing and changing the name of its Large and Mid-Size Business (LMSB) division as part of its ongoing effort to focus more on international tax compliance
FIN 48 and Tax Return Disclosure
This item provides a brief overview of the FIN 48 requirements, an update on the IRS plans, and some observations on the dynamics created among an engagement’s auditors, tax preparers, and client personnel resulting from these new rules.
Like-Kind Exchange Relief for Taxpayers Snared by Bankrupt Qualified Intermediaries
The IRS has finally provided a safe-harbor method to report gain or loss by taxpayers who are unable to complete a deferred like-kind exchange solely due to a qualified intermediary (QI) who defaults on its obligation to acquire and transfer replacement property.
The IRS’s Examination Workhorse: The Correspondence Audit
The AICPA has had active conversations with the IRS over the past several years about the difficulties taxpayers face with correspondence examinations.
Regs. Limiting Period for Filing Innocent Spouse Claim Held Valid
Reversing the Tax Court, the Seventh Circuit held that the two-year limitation period for filing an equitable innocent spouse claim under Sec. 6015(f) in Regs. Sec. 1.6015-5(b)(1) was valid.
TIGTA Finds IRS Doesn’t Always Protect Taxpayers, Follow Rules When Filing Liens
A report issued by TIGTA says the IRS does not always follow legal requirements when issuing liens and lien notices.
PTIN Fees Proposed by IRS
The IRS proposed to begin charging all authorized tax preparers a $50 user fee to obtain or renew annually a preparer tax identification number (PTIN).
IRS Launches Gulf Oil Spill Hotline, Plans Special Assistance Day
The IRS announced that it has set up a special toll-free telephone line for taxpayers affected by the oil spill in the Gulf of Mexico.
Sec. 6676: There’s a New Penalty in Town
The Small Business and Work Opportunity Tax Act of 2007 added a new taxpayer penalty under Sec. 6676 for erroneous refund claims, effective for claims filed or submitted after May 25, 2007.
National Taxpayer Advocate’s Report Notes Serious Problems
Nina Olson, the national taxpayer advocate, has presented her 2009 annual report to Congress. Her bottom-line finding is that “fundamental tax simplification is desperately needed.”
Using an Offer in Compromise
In these economic times, more taxpayers are not able to fully pay their federal income taxes when due. There are several methods that may be used to pay tax liabilities in this situation, one of which is an offer in compromise.
Refund Allowed After Carryback Recapture Held Entitled to Overpayment Interest
The Court of Federal Claims last year awarded the Coca-Cola Company overpayment interest on an overpayment of tax that previously had been (1) allowed as a tentative refund and then (2) recaptured and held for six years by the IRS.
Lack of Limitation Period on Certain Adjustments Affirmed in Recent Decision
A recent case illustrates that courts may sustain the government when it makes adjustments to closed years only to determine whether an overpayment of tax exists, and not to recover additional taxes beyond the limitation period on assessment.
AICPA Comments on IRS PTIN Proposal
On April 26, the AICPA submitted comments to the IRS on its proposed regulations (REG-134235-08) that would require tax return preparers, including nonsigning preparers, to apply for or renew a preparer tax identification number (PTIN) and exclusively use that PTIN when signing tax returns.
Go Easy on E-File Mandate, Committee Suggests
The preparer e-filing mandate effective next year should instead be phased in over three years, the Electronic Tax Administration Advisory Committee recommends. The committee also offers in its annual report recommendations on new proposed preparer oversight regulations and IRS computer systems modernization.
AICPA Submits Comments on IRS Uncertain Tax Position Proposal
The AICPA submitted comments to the IRS on the Service’s proposal to require certain business taxpayers to disclose their uncertain tax positions on their tax returns.
Sec. 199 Exam Status and Update
The Sec. 199 deduction has garnered increased attention in IRS exams over the past two years.
IRS Questions Willfulness Standard in Circular 230 Proceedings
This item summarizes the current definition of “willfulness” for purposes of Circular 230.
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.