Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Revenue Ruling

IRS correction; overpayment and underpayment rates increase 1% for second quarter, 2016

IRS correction; overpayment and underpayment rates increase 1% for second quarter, 2016

Rev Rul 2016-6, 2016-13 IRB; IR 2016-41 IRS has announced that the interest rates for tax overpayments and underpayments will increase by one percentage point for the second quarter of 2016. Note: Earlier this week, IRS issued versions of the above Revenue Ruling and Information Release that provided that rates had not changed for the second […]

Read the full article →

IRS Revokes Prior Ruling, Upholds Tax-Free Exchange & Nonrecognition Treatment

IRS Revokes Prior Ruling, Upholds Tax-Free Exchange & Nonrecognition Treatment

Rev Rul 2015-9, 2015-21 IRB   IRS has issued a Revenue Ruling in which it concluded that a transaction involving a series of stock transfers among a domestic parent and its foreign subsidiaries, and the liquidation of several existing subsidiaries, qualified as a tax-free Code Sec. 351 exchange followed by a series of type D […]

Read the full article →

IRS sets out tax treatment of a series of intercompany transfers of a wholly-owned LLC

IRS sets out tax treatment of a series of intercompany transfers of a wholly-owned LLC

Rev Rul 2015-10, 2015-21 IRB   In a Revenue Ruling, IRS has set out the tax treatment of a series of transfers of a wholly-owned limited liability company (LLC) taxable as a corporation from a parent corporation to its subsidiary and then successively to two lower-level subsidiaries, followed by the LLC electing to be treated […]

Read the full article →

IRS clarifies when metals used in manufacturing process are subject to depreciation

IRS clarifies when metals used in manufacturing process are subject to depreciation

Rev Rul 2015-11, 2015-21 IRB   In a Revenue Ruling, IRS has held that in determining whether metals, that are used up or whose purity declines as part of the process of manufacturing a product, are subject to depreciation, is based on an examination of the specific facts relating to the metal’s use in a […]

Read the full article →

Overpayment and underpayment rates remain the same for the first quarter of 2015

Overpayment and underpayment rates remain the same for the first quarter of 2015

Rev Rul 2014-29, 2014-52 IRB; IR 2014-111 IRS has announced that the interest rates for tax overpayments and underpayments for the calendar quarter beginning Jan. 1, 2015 will remain the same as for the fourth quarter of 2014. Note: The interest rates for tax overpayments and underpayments have remained constant for fourteen quarters in a […]

Read the full article →

IRS Updates Guidance On Use Of Electronic Media To Provide Employee Transportation Benefits

IRS Updates Guidance On Use Of Electronic Media To Provide Employee Transportation Benefits

Rev Rul 2014-32, 2014-50 IRB In a Revenue Ruling, IRS has provided guidance, in the form of a series of factual situations, on the use of smartcards, debit or credit cards, or other electronic media to provide qualified transportation fringe benefits to employees, as well as on the use by employees of debit cards for […]

Read the full article →

Applicable Federal Rates for December

Applicable Federal Rates for December

Rev Rul 2014-31, 2014-50 IRB The Applicable Federal Rates for December 2014 are reproduced below. Table 1 Applicable Federal Rates (AFR) for December 2014 Period for Compounding Annual Semiannual Quarterly Month Short-Term AFR .34% .34% .34% .34% 110% AFR .37% .37% .37% .37% 120% AFR .41% .41% .41% .41% 130% AFR .44% .44% .44% .44% […]

Read the full article →

Puerto Rican qualified plans & insurance co. separate accounts can pool assets in group trust

Puerto Rican qualified plans & insurance co. separate accounts can pool assets in group trust

Rev Rul 2014-24, 2014-37 IRB In a Revenue Ruling, IRS has included trusts of certain retirement plans qualified only under the Puerto Rico Code (the Código de Rentas Internas para un Nuevo Puerto Rico de la Ley Núm. 1 de 31 de enero de 2011) in the list of group trust retiree benefit plans eligible […]

Read the full article →

IRS designates depreciation class for assets used to convert corn to ethanol

IRS designates depreciation class for assets used to convert corn to ethanol

Rev Rul 2014-17, 2014-24 IRB. IRS has announced that, with very limited exceptions, the proper asset class for depreciation of tangible assets used in converting corn to fuel grade ethanol is asset class 49.5. Assets in class 49.5 have a recovery period of 7 years for purposes of the general depreciation system (Code Sec. 168(a)) […]

Read the full article →

Employer’s funding of retiree benefits via wholly owned subsidiary constitutes insurance

Employer’s funding of retiree benefits via wholly owned subsidiary constitutes insurance

In Revenue Ruling 2014-15, 2014-22 IRB, IRS has concluded that an arrangement whereby an employer funds its retiree health benefits through a wholly owned subsidiary constitutes insurance for federal income tax purposes, and the subsidiary is an insurance company for both state and federal tax law purposes. Background. Under Code Sec. 801(a), a life insurance […]

Read the full article →

IRS determines end-of-year life insurance reserves for variable contracts

IRS determines end-of-year life insurance reserves for variable contracts

In Revenue Ruling 2014-7, 2014-9 IRB, IRS has determined the amount of the life insurance reserves taken into account under Code Sec. 807 for a variable contract where some or all of the reserves were accounted for as part of a life insurance company’s separate account reserves. Background. In general, life insurance companies are taxed […]

Read the full article →

What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

Read the full article →

IRS describes situations where plan administrator may reasonably find a valid rollover

IRS describes situations where plan administrator may reasonably find a valid rollover

In Revenue Ruling 2014-9, 2014-17 IRB, IRS has provided two fact patterns under which, in the absence of evidence to the contrary, the plan administrator of a receiving plan will be deemed to have reasonably concluded that an amount received was a valid rollover contribution. Thus, for purposes of the receiving plan’s qualification status, the […]

Read the full article →

IRS determines end-of-year life insurance reserves for variable contracts

IRS determines end-of-year life insurance reserves for variable contracts

In a Revenue Ruling, Rev. Ruling 2014-7, 2014-9 I.R.B., IRS has determined the amount of the life insurance reserves taken into account under Code Sec. 807 for a variable contract where some or all of the reserves were accounted for as part of a life insurance company’s separate account reserves. Background. In general, life insurance […]

Read the full article →

Amounts collected by health insurers to offset annual fee are included in income

Amounts collected by health insurers to offset annual fee are included in income

In a Revenue Ruling, Rev Rul 2013-27, 2013-51 IRB, IRS has clarified that amount collected by a covered entity from policyholders to offset the cost of the post-2013 annual fee on health insurance providers is included in the covered entity’s gross income under Code Sec. 61(a). Background.  Under Code Sec. 61(a), gross income means all […]

Read the full article →

Revenue Ruling 2013-25

Revenue Ruling 2013-25

Revenue Ruling 2013-25 provides the rates for interest on tax overpayments and underpayments for the calendar quarter beginning January 1, 2014.  The interest rates will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for underpayments, 0 and one-half percent for the portion of a corporate overpayment exceeding 10,000, […]

Read the full article →

IRS adopts “state of celebration” rule in recognizing same-sex marriages: IR 2013-72; Rev Rul 2013-17, 2013-38 IRB

IRS adopts “state of celebration” rule in recognizing same-sex marriages:  IR 2013-72; Rev Rul 2013-17, 2013-38 IRB

We blogged that “Treasury and IRS Announce That All Legal Same-Sex Marriages Will Be Recognized For Federal Tax Purposes; Ruling Provides Certainty, Benefits and Protections Under Federal Tax Law for Same-Sex Married Couples.” This blog expands on that announcement. In IR 2013-72; Rev Rul 2013-17, 2013-38 IRB, IRS has issued much anticipated guidance explaining the […]

Read the full article →

SEC Freezes Assets of Missing Georgia-Based Investment Adviser

SEC Freezes Assets of Missing Georgia-Based Investment Adviser

Editor’s Note:  often in the cases we handle there are cross investigations with different federal and/or state agencies.  One example, is the Securities and Exchange Commission.  This news event caught my eye and it is fairly typical of what happens – – Ponzi scheme, investor losses, IRS investigation, no deduction or limited deductions [read:  Bernie […]

Read the full article →

IRS Rev. Ruling 2012-19: Section 162(m)(4)(C) – Dividends and Dividend Equivalents on Restricted Stock and Restricted Stock Units

IRS Rev. Ruling 2012-19: Section 162(m)(4)(C) – Dividends and Dividend Equivalents on Restricted Stock and Restricted Stock Units

Editor’s Note:  frequently, clients have questions regarding their compensation and “restricted stock.”  Stock options are a rather tricky and laborious process so there are no easy answers.  Recently, the IRS issued Revenue Ruling-2012-19, which discusses Section 162(m)(4)(C),Dividends and Dividend Equivalents on Restricted Stock and Restricted Stock Units.  The issue is whether dividends and dividend equivalents […]

Read the full article →
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.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney