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Revision to accounting method change Rev Proc provides liberal transition rule

Revision to accounting method change Rev Proc provides liberal transition rule

Rev Proc 2015-13, 2015-5 IRB 419   IRS has issued a revised version of Rev Proc 2015-13, which provides the general procedures under which taxpayers obtain IRS consent to change a method of accounting. The revised version provides taxpayers with a more liberal transition rule than was provided in the original version of Rev Proc […]

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Proposed reliance regs no longer require copy of Code Sec. 83(b) election with return

Proposed reliance regs no longer require copy of Code Sec. 83(b) election with return

Preamble to Prop Reg 07/16/2015, Prop Reg § 1.83-2 To remove obstacles to e-filing an individual tax return, IRS has issued proposed regs which eliminate the requirement that taxpayers must submit a copy of a Code Sec. 83(b) election with their tax returns for the year in which the property subject to the election was […]

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LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

A recently released memorandum to all employees at IRS’s Large Business and International (LB&I) Division provides guidance to IRS examiners on how to determine when a major component pertaining to steam or electric generation property has been replaced under Reg. § 1.263(a)-3(k). The memo generally provides that a major component is considered to be replaced, […]

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Recently-enacted law contains tax return filing due dates changes

Recently-enacted law contains tax return filing due dates changes

The recently enacted “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015” (P.L. 114-41) contains significant changes to filing deadlines and extensions for certain business and special entity tax returns. On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” […]

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Washington Alert – TIGTA faults ITIN procedures; Applications open for ACT; IRS Reference Guide updated on FBARs; US & Turkey sign FACTA agreement

Washington Alert – TIGTA faults ITIN procedures; Applications open for ACT; IRS Reference Guide updated on FBARs; US & Turkey sign FACTA agreement

A Treasury Inspector General for Tax Administration (TIGTA) audit released on Aug. 6 found that IRS’s Individual Taxpayer Identification Number (ITIN) application processes and procedures do not ensure that documents certified by a foreign issuing agency are authentic. (Audit Report No. 2015-40-038) An ITIN is issued to individuals who are required to have a Taxpayer […]

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Tax Court holds Taxpayer who generally lived at casino hotel wasn’t professional gambler

Tax Court holds Taxpayer who generally lived at casino hotel wasn’t professional gambler

Boneparte, TC Memo 2015-128 The Tax Court has ruled that a taxpayer was not a professional gambler even though he gambled regularly, did not maintain a permanent residence, and generally stayed in Atlantic City, New Jersey casino hotels. Background. Code Sec. 162(a) allows deductions for ordinary and necessary expenses paid or incurred during the tax year […]

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Fees to Rise for Freedom of Information Act Document Searches

Fees to Rise for Freedom of Information Act Document Searches

The SEC amended its rules under the Freedom of Information Act for fees it collects to carry out requests for agency information and documents. The rule changes include a more-than 200 percent rise in the base rates, which are tied to the compensation and seniority of the SEC staffers handling the requests. The SEC on […]

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U.S. agency overseeing sanctions faces brain drain, added work

U.S. agency overseeing sanctions faces brain drain, added work

WASHINGTON (Reuters) – As Congress considers a controversial nuclear deal with Iran, the U.S. Treasury agency charged with implementing related financial sanctions is at risk of being overwhelmed by its expanding mission, former employees and lawyers who deal with the office say. The agency, the Office of Foreign Assets Control, is responsible for enforcing a […]

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U.S. budget deficit widens to $149.2 billion in July

U.S. budget deficit widens to $149.2 billion in July

WASHINGTON (Reuters) – The United States posted a budget deficit of $149.2 billion in July, up 58 percent from the same period last year, the U.S. Treasury Department said on Wednesday. Analysts polled by Reuters had expected a $132 billion deficit for July. The government had a deficit of $94.6 billion in July of 2014, […]

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Revised effective date for small wind energy property standards

Revised effective date for small wind energy property standards

Notice 2015-51, 2015-31 IRB IRS has revised the effective date of Notice 2015-4, which set out standards for small wind energy property to qualify for the energy credit. Background. A taxpayer can claim 30% energy credits for qualified small wind energy property. (Code Sec. 48(a)(3)(A)(vi)) This is property that uses a qualifying small wind turbine […]

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Restitution paid to government as part of business crime plea deal was deductible

Restitution paid to government as part of business crime plea deal was deductible

PLR 201528026 In a private letter ruling, IRS has held that a principal in a business could deduct the amount he paid to the U.S. government as restitution, as part of a plea deal resulting from his pleading guilty to a crime committed in the course of his employment.  Click here for the PLR. Background. […]

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Washington Alert – IRS warns of New Tricks by Scam Artists; Budget Deficit

Washington Alert – IRS warns of New Tricks by Scam Artists; Budget Deficit

Spurred by “the emergence of new variations of widespread tax scams,” IRS on Aug. 6 has again warned taxpayers to remain vigilant in the face of “the ever evolving array of deceitful tactics scammers use to trick people.” (IR 2015-99) According to the agency, a common element of the scams is fear, with scammers attempting […]

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Bits ’n Pieces – emails show IRS’s Lerner had choice words for conservatives

Bits ’n Pieces – emails show IRS’s Lerner had choice words for conservatives

Emails show IRS’s Lois Lerner had choice words for conservatives. By John D. McKinnon – The emails show Ms. Lerner denouncing the Supreme Court’s Citizens United decision – widely hailed by conservatives – as a death-knell of democracy; and bemoaning President Lincoln’s success in keeping the South in the Union. Link to The Wall Street […]

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Tax Court – Purported welfare benefit plan was split-dollar life insurance arrangement

Tax Court – Purported welfare benefit plan was split-dollar life insurance arrangement

Our Country Home Enterprises, Inc., et al., 145 TC No. 1 In consolidated cases, the Tax Court has concluded that the life insurance policies issued on the lives of shareholder/employees incident to their participation in a purported welfare benefit plan were part of a split-dollar life insurance arrangement. Further, the Court determined that the corporate […]

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Tax Court: Stock issued to employee/49.75% owner wasn’t subject to substantial risk of forfeiture

Tax Court: Stock issued to employee/49.75% owner wasn’t subject to substantial risk of forfeiture

QinetiQ U.S. Holdings Inc., TC Memo 2015-123 The Tax Court has held that where a corporation issued 49.75% of its stock to an employee shortly after the formation of the corporation, a successor corporation could not take a compensation deduction with respect to the stock many years later. There was some question as to whether […]

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Washington Alert – CMS concerned of loss of ACA’s premium tax credit; IRS Collection being proactive on payroll taxes; JCT Report onMacroeconomic Effects of the ‘Tax Relief Extension Act of 2015

Washington Alert – CMS concerned of loss of ACA’s premium tax credit; IRS Collection being proactive on payroll taxes; JCT Report onMacroeconomic Effects of the ‘Tax Relief Extension Act of 2015

Federal officials, including those at the Centers for Medicare and Medicaid Services (CMS), are continuing to voice concerns regarding the possibility that up to an estimated 1.8 million households could lose their eligibility to receive the Affordable Care Act’s premium tax credit in 2016. Based on Treasury Department data, these households have been receiving the […]

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IRS disagrees with partner exclusion of partnership’s debt cancellation income

IRS disagrees with partner exclusion of partnership’s debt cancellation income

AOD 2015-001, 02/09/2015   In an Action on Decision (AOD), IRS has announced its nonacquiesence with four Tax Court cases each of which held that a partner, who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity, may exclude from gross income under Code Sec. 108(a), partnership debt cancelled […]

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Regs will ban replacing defined benefit plan lifetime income with lump sum payment

Regs will ban replacing defined benefit plan lifetime income with lump sum payment

Notice 2015-49, 2015-30 IRB IRS has announced that it will amend the required minimum distribution (RMD) regs to provide that qualified defined benefit plans generally are not allowed to replace any joint and survivor, single life, or other annuity that is currently being paid with a lump sum payment or other accelerated form of distribution. […]

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Tax Court: Taxpayer was owner of accounts under “investment control” doctrine

Tax Court: Taxpayer was owner of accounts under “investment control” doctrine

Webber, (2015) 144 TC No. 171 The Tax has concluded that, under the “investment control” doctrine, the taxpayer who established a grantor trust that purchased “private placement” variable life insurance policies insuring the lives of two elderly relatives was the actual owner of the assets in the separate accounts underlying the policies. Note: Where the […]

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Overstock chairman has political missions in Washington DC and Utah

Overstock chairman has political missions in Washington DC and Utah

WASHINGTON (Reuters) – This year, Jonathan Johnson is a man with two political missions. In his home state of Utah, the Overstock.com Inc chairman is preparing a 2016 bid to replace a popular governor. In Washington DC, his online retailer has emerged as the only company to back both of two competing proposals in Congress […]

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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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