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Blog & Articles

Proposed reliance regs on taxation, withholding, reporting of adjustments to stock rights

Proposed reliance regs on taxation, withholding, reporting of adjustments to stock rights

Preamble to Prop Reg 04/12/2016; Prop Reg § 1.305-1, Prop Reg § 1.305-3, Prop Reg § 1.305-7 , Prop Reg § 1.860G-3, Prop Reg § 1.861-3, Prop Reg § 1.1441-2, Prop Reg § 1.1441-3, Prop Reg § 1.1441-7 , Prop Reg § 1.1461-2 , Prop Reg § 1.1471-2, Prop Reg § 1.1473-1, Prop Reg § […]

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Washington Alert – IRS needs more employees; IRS seeking applicants for Internal Revenue Service Advisory Council (IRSAC); TIGTA report on premium tax credit (PTC) claims; IRS accepting applications for the Tax Counseling for the Elderly (TCE) and Volunteer Income Tax Assistance (VITA) grant programs

Washington Alert – IRS needs more employees; IRS seeking applicants for Internal Revenue Service Advisory Council (IRSAC); TIGTA report on premium tax credit (PTC) claims; IRS  accepting applications for the Tax Counseling for the Elderly (TCE) and Volunteer Income Tax Assistance (VITA) grant programs

IRS will soon begin the first wave of a plan to hire up to 700 employees to serve in enforcement positions, IRS Commissioner John Koskinen told agency employees in a May 3 memo. This will mark “the first significant enforcement hiring in over five years,” Koskinen wrote. The initial wave of hiring will fill entry-level […]

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Conservatives in Congress urge shutdown of U.S. tax collector

Conservatives in Congress urge shutdown of U.S. tax collector

WASHINGTON (Reuters) – It’s a U.S. taxpayer’s dream: make the Internal Revenue Service go away, and the largest conservative group in Congress is endorsing just that. The Republican Study Committee, which counts over two-thirds of House of Representatives Republicans as its members, called recently for “the complete elimination of the IRS.” The committee’s support for […]

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Companies put $221 billion into low-tax jurisdictions in 2015 – U.N.

Companies put $221 billion into low-tax jurisdictions in 2015 – U.N.

GENEVA (Reuters) – Companies put $221 billion into countries with low tax last year, chiefly Luxembourg and the Netherlands, while $72 billion of investment went into two British tax havens – the British Virgin Islands and Cayman Islands, the U.N. said on Tuesday. However, they took billions out of Luxembourg and the Netherlands in the final […]

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Final material advisor list penalty reg somewhat less harsh than earlier proposed reg

Final material advisor list penalty reg somewhat less harsh than earlier proposed reg

T.D. 9764, 04/27/2016; Reg. § 301.6708-1 IRS has issued a final reg on the Code Sec. 6708 penalty for material advisors’ failure to make available upon IRS’s request lists of advisees with respect to reportable transactions. The final reg makes a number of changes to the proposed reg, most of which will somewhat lessen the […]

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IRS will withdraw parts of recently-issued proposed pension plan nondiscrimination regs

IRS will withdraw parts of recently-issued proposed pension plan nondiscrimination regs

Ann. 2016-16, 2016-18 IRB IRS has announced that it will withdraw certain provisions contained in proposed regs issued this past January that would have changed nondiscrimination requirements applicable to qualified retirement plans. Background — before the proposed regs. In general, under Code Sec. 401(a)(4), a plan is a qualified plan only if the contributions or […]

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Washington Alert – IRS & National Small Business Week; tax gap for 2008-2010 is $458 billion; DOJ reminder to employers re withholding

Washington Alert – IRS  & National Small Business Week; tax gap for 2008-2010 is $458 billion; DOJ reminder to employers re withholding

IRS has announced that it is promoting National Small Business Week by offering a series of educational webinars to help small business owners and self-employed individuals “not only to be tax compliant, but also to help their businesses thrive.” (IR 2016-68) As described by the agency, each webinar topic has a tax tip or fact […]

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Obama: new tax rule will fight corruption, help economy

Obama: new tax rule will fight corruption, help economy

WASHINGTON (Reuters) – U.S. President Barack Obama said on Friday a long-delayed rule requiring the financial industry to identify the real owners of companies will help fight corruption and tax evasion and boost the economy. His administration on Friday issued the Customer Due Diligence rule in the works since 2012 and proposed legislation meant to […]

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How Barclays turned a $10 billion profit into a tax loss

How Barclays turned a $10 billion profit into a tax loss

LONDON (Reuters) – When Barclays Plc sold a fund management business to U.S. financial group Blackrock Inc. in 2009, the larger-than-expected $15.2 billion price tag was not the only good news for the British bank’s investors. The way Barclays structured the sale — by booking part of the proceeds in Luxembourg — allowed it to […]

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Trump wants to help U.S. businesses by lifting slew of regulations – CNBC

Trump wants to help U.S. businesses by lifting slew of regulations – CNBC

WASHINGTON (Reuters) – Republican presidential candidate Donald Trump outlined economic policy initiatives on Thursday that he would pursue if elected to the White House in November, including refinancing longer-term U.S. debt, lowering taxes and scrapping a slew of federal regulations. The Manhattan real estate mogul said his aim would be to clear the way for […]

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No Tax Court jurisdiction in worker classification case because there was no IRS audit

No Tax Court jurisdiction in worker classification case because there was no IRS audit

B G Painting, TC Memo 2016-62 The Tax Court has held that IRS’s determination that a taxpayer’s worker was its employee, in response to the employee’s request for that determination under IRS’s SS-8 program, did not meet the criteria necessary to provide the Tax Court with jurisdiction over the taxpayer’s petition to review IRS’s determination. […]

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Taxpayer must report share of partnership income even though he was unaware there was income

Taxpayer must report share of partnership income even though he was unaware there was income

Lamas-Richie, TC Memo 2016-63TC Memo 2016-63 The Tax Court has concluded that a gossip blogger was liable for tax on his distributive share of partnership income that was not actually distributed to him and of which he was not aware until IRS began examining his return for the year at issue. However, the Court declined […]

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Jet service activity wasn’t for profit, so taxpayer can’t claim losses in excess of income

Jet service activity wasn’t for profit, so taxpayer can’t claim losses in excess of income

Hoffmann, TC Memo 2016-69 The Tax Court has concluded that a taxpayer was not entitled to deduct losses from his jet service activity that exceeded the amount of income derived therefrom because the activity was not conducted with the intent of generating a profit. The Court found that, contrary to the taxpayer’s argument that he […]

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Tax Court – no clear link from financial problems to not paying tax, so penalties, liens, levies applied

Tax Court – no clear link from financial problems to not paying tax, so penalties, liens, levies applied

Nutrition Formulators Inc., TC Memo 2016-60 The Tax Court has held that an employer did not have reasonable cause that would excuse penalties for failure to deposit employment taxes, failure to pay employment taxes shown on its return and failure to timely file a return, and that IRS settlement officers acted properly in sustaining lien […]

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“Bad boy” carve-outs don’t automatically end treatment as nonrecourse liability

“Bad boy” carve-outs don’t automatically end treatment as nonrecourse liability

Legal Advice Issued by Associate Chief Counsel 2016-001 Legal Advice Issued by Associate Chief Counsel, “Nonrecourse Carve-Out” Guarantee of a Partnership Liability. In Legal Advice Issued by Associate Chief Counsel, IRS — reversing its previous position — has concluded that if a partner’s guarantee of a partnership’s nonrecourse obligation is conditioned on the occurrence of […]

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Swaps and captive REIT liquidations won’t sour REIT prohibited transactions safe harbor

Swaps and captive REIT liquidations won’t sour REIT prohibited transactions safe harbor

PLR 201614009 IRS has privately ruled that a real estate investment trust’s (REIT’s) like-kind exchanges won’t be treated as sales for purposes of the Code Sec. 857(b)(6)(C) prohibited transactions safe harbor, but that gain recognized on boot received in such exchanges may be treated as a sale for that safe harbor. IRS also ruled that […]

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CA-1 finds its standards for examining agents in summons cases largely unaltered by Clarke

CA-1 finds its standards for examining agents in summons cases largely unaltered by Clarke

Gangi, et al, v. U.S., (CA 1 3/30/2016) 116 AFTR 2d ¶2016-573 The Court of Appeals for the First Circuit, affirming a district court, has determined that its standard for determining whether a taxpayer is entitled to examine an IRS employee’s motive for issuing a summons is, for purposes of the instant case, consistent with […]

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California’s rule that it receive nonprofit’s Form 990 information held unconstitutional

California’s rule that it receive nonprofit’s Form 990 information held unconstitutional

Americans For Prosperity Foundation. v. Harris, (DC CA 4/21/2016) 117 AFTR 2d ¶ 2016-644 A U.S. district court has held that the state of California’s requirement that tax-exempt organizations submit IRS Form 990 Schedule B, which discloses names and contributions of significant donors, to the state is unconstitutional in its application to the organization that […]

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Comments Sought on Controversial Political Spending Disclosure Rule

Comments Sought on Controversial Political Spending Disclosure Rule

Despite the restrictions imposed upon the SEC by Congress, the regulatory agency appears to be sustaining a contentious debate about public company disclosures for political activity in a request for comments that is part of a document soliciting views about the agency’s overall disclosure regime. The SEC asked for comments on the usefulness of public […]

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Online Tool Helps Companies Estimate Fees for EDGAR Filings

Online Tool Helps Companies Estimate Fees for EDGAR Filings

The SEC unveiled a tool that it said helps companies estimate their expenses for filing regulatory documents on the agency’s EDGAR system. The tool prompts users to enter data based on the type of filing and the applicable fees, and it provides suggestions for completing required fee tables based on the data entered. The SEC […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney