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Blog & Articles

Rev Proc provides detailed guidance on depreciation changes under TIPA

Rev Proc provides detailed guidance on depreciation changes under TIPA

Rev Proc 2015-48, 2015-40 IRB In a Revenue Procedure, IRS has provided guidance on changes made by the Tax Increase Prevention TIPA of 2014 (TIPA, P.L. 113-295) to provisions dealing with Code Sec. 168(k) bonus depreciation, the Code Sec. 168(k)(4) election to forego bonus depreciation and increase the alternative minimum tax credit, and the Code […]

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More disaster victims in California qualify for tax relief

More disaster victims in California qualify for tax relief

Victims of recent severe storms and flooding in numerous states have more time to make tax payments and file returns if they are affected taxpayers in counties that have been designated as federal disaster areas qualifying for individual assistance. Certain other time-sensitive acts also are postponed. IRS has recently announced on its website that an […]

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IRS offers preview of proposed regs on health insurance coverage reporting

IRS offers preview of proposed regs on health insurance coverage reporting

Notice 2015-68, 2015-41 IRB In a Notice, IRS has advised taxpayers of its intent to issue proposed regs under Code Sec. 6055 that would, among other things, clarify reporting requirements with respect to catastrophic health insurance plans enrolled in through an Exchange and modify the existing “supplemental coverage rule.” The Notice also provides penalty relief […]

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IRS will amend FATCA regs to extend various transitional rules

Notice 2015-66, 2015-41 IRB In a Notice, IRS has announced that it will amend the Foreign Account Tax Compliance Act (FATCA) regs to extend the period of time that certain transitional rules will apply and to modify the rules for grandfathered obligations in relation to collateral held by withholding agents. The Notice also provides information […]

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Donee’s assumption of Code Sec. 2035(b) estate liability reduced value of gift

Donee’s assumption of Code Sec. 2035(b) estate liability reduced value of gift

Jean Steinberg, Donor, (2015) 145 TC No. 7 The Tax Court has concluded that where a taxpayer gave her children property in exchange for their promise to pay any estate tax liability arising under Code Sec. 2035(b)’s “gross-up rule”—which increases a decedent’s gross estate by the amount of any gift tax paid by the decedent […]

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Tax Court – Turning debt over to collection agency didn’t overcome presumption of uncollectibility

Tax Court – Turning debt over to collection agency didn’t overcome presumption of uncollectibility

Clark, TC Memo 2015-175 The Tax Court has held that the mere fact that a financial institution creditor turned over a debt to a collection agency after the expiration of the non-payment period described in Reg. § 1.6050P-1(b)(2)(i)(H) was insufficient to overcome a rebuttable presumption in the regs that the debt had already been discharged. […]

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Washington Alert – Change in LB&I Division;TIGTA report on IRS options re payment;IRS on ACA – Applicable Large Employers;The Pension Benefit Guaranty Corporation publishes final rule on reportable events

Washington Alert – Change in LB&I Division;TIGTA report on IRS options re payment;IRS on ACA – Applicable Large Employers;The Pension Benefit Guaranty Corporation publishes final rule on reportable events

A big shakeup is underway for IRS’s Large Business and International (LB&I) Division, and its new look will be launched in the early months of 2016, according to Douglas O’Donnell, commissioner of the division. O’Donnell and several other agency officials revealed a number of key details during their appearance at a Sept. 17 conference in […]

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Final F reorganization regs cover qualifications & outbound transactions

Final F reorganization regs cover qualifications & outbound transactions

T.D. 9739, 09/18/2013, Reg. § 1.367(a)-1, Reg. § 1.367(a)-1T, Reg. § 1.368-2 IRS has issued final regs that provide guidance on the qualification for a corporate reorganization under Code Sec. 368(a)(1)(F) (F reorganization, i.e., a mere change of identity, form, or place of organization of one corporation). IRS has also issued final regs under Code […]

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Application of jeopardizing investment excise tax to non-program-related investments

Application of jeopardizing investment excise tax to non-program-related investments

Notice 2015-62, 2015-39 IRB In a Notice, IRS has provided guidance on the application of the excise tax under Code Sec. 4944 to investments that are made by private foundations for charitable purposes described in Code Sec. 170(c)(2)(B), but do not meet the other requirements to qualify as program-related investments (PRIs) excepted from treatment as […]

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Second Circuit: banking corporation can deduct interest paid on STARS-related loan

Second Circuit: banking corporation can deduct interest paid on STARS-related loan

The Bank of New York Mellon Corporation v. Comm., (CA 2 9/9/2015) 116 AFTR 2d ¶ 2015-5219 The Court of Appeals for the Second Circuit, affirming the Tax Court, has held that a $1.5 billion loan that a banking corporation took out in association with a structured trust advantaged repackaged securities (STARS) transaction had independent […]

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VW’s diesel tax breaks could be a focus for U.S. prosecutors

VW’s diesel tax breaks could be a focus for U.S. prosecutors

WASHINGTON (Reuters) – Volkswagen’s <VOWG_p.DE> push to secure tax breaks that kick-started a market for its new diesel cars could now help U.S. investigators build a case against the automaker for deceiving the government about their emissions, lawyers said. VW was among several automakers that lobbied the administration of George W. Bush to secure around […]

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Developer’s advances to municipality for infrastructure were costs of real property

Developer’s advances to municipality for infrastructure were costs of real property

Chief Counsel Advice 201537022 In Chief Counsel Advice, IRS has concluded that: a) amounts advanced by a real estate developer to a special municipal district for the construction of infrastructure for the developer’s real estate project were costs of developing the real property; and b) the developer must treat any repayments from the district, whether […]

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IRS describes areas of concern under Code Sec. 355 & expands no-rule areas

IRS describes areas of concern under Code Sec. 355 & expands no-rule areas

Notice 2015-59, 2015-40 IRB, Rev Proc 2015-43, 2015-40 IRB In a Notice, IRS has announced that it is studying issues under Code Sec. 355 (and Code Sec. 337(d)) relating to certain distributions, described in Code Sec. 355, in which property becomes the property of a regulated investment company (RIC) or a real estate investment trust […]

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How capitalization regs’ safe harbor boosts year-end deductions despite Sec. 179 cutback

How capitalization regs’ safe harbor boosts year-end deductions despite Sec. 179 cutback

Businesses that have benefitted from the generous $500,000 Code Sec. 179 expensing limit for tangible personal property (and certain software) for the past few years may be in for an unwelcome surprise this year. Unless Congress acts to retroactively restore generous expensing, starting with qualified property placed in service in tax years beginning after 2014, […]

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IRS will amend FATCA regs to extend various transitional rules

Notice 2015-66, 2015-41 IRB In a Notice, IRS has announced that it will amend the Foreign Account Tax Compliance Act (FATCA) regs to extend the period of time that certain transitional rules will apply and to modify the rules for grandfathered obligations in relation to collateral held by withholding agents. The Notice also provides information […]

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IRS explains how retirement plan administrators request waiver of electronic filing requirement

IRS explains how retirement plan administrators request waiver of electronic filing requirement

Rev Proc 2015-47, 2015-39 IRB In a Revenue Procedure, IRS has set forth procedures for plan administrators of retirement plans (or, in certain situations, employes maintaining retirement plans) that are required to file electronically Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, and Form 5500-EZ, Annual Return of One-Participant (Owners and […]

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Payment of option fee in Colorado pawnshop transaction may trigger cash reporting

Payment of option fee in Colorado pawnshop transaction may trigger cash reporting

Chief Counsel Advice 201536022 In e-mailed Chief Counsel Advice (CCA), IRS has concluded that the payment fee in connection with a Colorado pawnshop contract for purchase is a “retail sale” that can trigger the Code Sec. 6050I reporting requirement for cash receipts of more than $10,000. Background.Code Sec. 6050I generally requires each person engaged in […]

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Disaster victims in California qualify for tax relief

Disaster victims in California qualify for tax relief

IRS has announced on its website that victims of the valley fire in a county of California that is designated as federal a disaster area qualifying for individual assistance have more time to make tax payments and file returns. Certain other time-sensitive acts also are postponed. This article summarizes the relief that’s available and includes […]

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Final, etc. Regs on Payments Determined by Reference to U.S. Source Dividends

Final, etc. Regs on Payments Determined by Reference to U.S. Source Dividends

T.D. 9734, 09/17/2015; Reg. § 1.871-14, Reg. § 1.871-15, Reg. § 1.871-15T , Reg. § 1.1441-1, Reg. § 1.1441-1T, Reg. § 1.1441-2 , Reg. § 1.1441-3, Reg. § 1.1461-1, Reg. § 1.1441-7 , Reg. § 1.1473-1; Preamble to Prop Reg 09/17/2015; Prop Reg § 1.871-15 , Prop Reg § 1.1441-1 IRS has issued final regs, […]

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IRS Notice describes areas of concern under Code Sec. 355

IRS Notice describes areas of concern under Code Sec. 355

Notice 2015-59, 2015-40 IRB, Rev Proc 2015-43, 2015-40 IRB In a Notice, IRS has announced that it is studying issues under Code Sec. 355 (and Code Sec. 337(d)) relating to certain distributions, described in Code Sec. 355, in which property becomes the property of a regulated investment company (RIC) or a real estate investment trust […]

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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