For purposes of determining whether there had been a substantial understatement of gross income on a taxpayer’s return, the IRS determined that amounts on a Form 1120S filed after the three-year statute of limitation expired, were not considered to be disclosed on a taxpayer’s Form 1040.
This article examines how to determine the new surtax on net investment income that, like alternative minimum taxable income, effectively creates another tax base in addition to taxable income.
A taxpayer is not required to recognize taxable income for the discharge of a liability when payment of the liability would have given rise to a tax deduction.
Investors in hedge funds may be subject to higher federal tax rates and the new 3.8% net investment income tax (also known as the unearned income Medicare contribution tax) in 2013.
The proposed regulations under Sec. 1411 do not provide a definition of “trade or business” for taxpayers engaged in rental real estate activities and thus potentially subject to the tax on net investment income on income from these activities.
Flight Attendant Cannot Claim Foreign Earned Income Exclusion for Wages Earned in International Airspace and U.S.
The Tax Court held that a flight attendant who was a resident of Hong Kong and a U.S. citizen could not claim 100% of her wages were excludable under the foreign earned income exclusion.
This article covers recent developments in individual taxation. The items are arranged in Code section order.
The IRS on Monday issued the 2013 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
There are various types of PTO donation and leave-sharing programs, not all of which are disaster-related. The tax treatment to the donating employee differs based on the type of program.
The Eleventh Circuit held that payments made to a taxpayer by limited partnerships that he controlled but did not own an interest in were compensation reportable on Schedule C, not partnership distributions.
The IRS has described four situations where employers have recharacterized taxable wages as nontaxable business expense reimbursements and has ruled on whether these arrangements satisfy the business connection requirement of the accountable plan rules.
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.
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.
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.
This article covers recent developments affecting individual taxation.
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.
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.
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.
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.
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.