IRS Provides Guidance on Contributions to HSAs

Article:  The Tax Relief and Health Care Act of 2006, P.L. 109-432, made changes to the treatment of contributions to health savings accounts (HSAs) under Sec. 223. The IRS issued two notices explaining those changes.
Published on January 28, 2011

Tax-Deferred Exchanges of Vacation Homes

Article:  The IRS carved out a safe harbor for the exchange of vacation homes to qualify for Sec. 1031 treatment.
Published on January 28, 2011

Income Splitting Issues and Opportunities

Article:  Tax law generally prohibits a parent from shifting income from personal services to a child; however, a parent can in some cases effectively shift income to a child by transferring income-producing property to the child.
Published on January 28, 2011

Teaching Tax Through the Socratic Method

Article:  This column explores a type of active learning pedagogy that university and continuing education instructors should consider using in order to help students attain more permanent and meaningful learning.
Published on July 22, 2010

TIGTA Test Uncovers Significant Errors in Returns Prepared by Unenrolled, Unlicensed Preparers

Article:  During February and March of 2008, TIGTA auditors posing as taxpayers paid to have individual tax returns prepared by 28 unenrolled, unlicensed tax preparers. TIGTA found significant errors in most of the returns prepared in the test.
Published on July 22, 2010

When Plaintiffs in Class Actions Pay Tax on Attorneys Fees

Article:  The taxation of attorneys’ fees in opt-out class actions has become relatively clear, as long as certain elements are established. In opt-in cases, class members risk being tagged with income in the amount of the attorneys’ fees.
Published on July 22, 2010

Widow of 9/11 Victim Is Not a Terrorist Victim

Article:  A federal court ruled, in a case of first impression, that a widow who committed suicide after her husband was killed in the 2001 World Trade Center attack does not qualify as a victim of terrorism and therefore her estate does not qualify for the reduced estate tax rates under
Published on July 22, 2010

Service Provides Guidance on Children of Divorced Parents

Article:  The IRS released guidance on the circumstances under which it will treat a child of parents who are divorced, separated, or living apart as the dependent of both parents for various purposes when the custodial parent has not released the claim to the child's exemption.
Published on July 06, 2010

Tax Aspects of Contributing a House to a Fire Department

Article:  Taxpayers can obtain a charitable contribution deduction for the fair market value of property donated to a fire department to be burned down. The taxpayer needs to properly structure the transaction so that the property, and not just the right to use the property, is being donated.
Published on July 06, 2010

Tax Court May Not Disregard Findings of a Special Trial Judge

Article:  The Fifth Circuit held that the Tax Court did not give due regard to the findings of its special trial judge and ordered the Tax Court to issue a final order adopting the findings in that judge's report.
Published on July 06, 2010

Selected Provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty

Article:  In 2007, the United States and Canada signed the Fifth Protocol to the 1980 U.S.-Canada Income Tax Treaty. The changes to the treaty resulting from this new protocol are numerous and are quite significant for cross-border business
Published on July 06, 2010

SEC Approves Early IFRS Adoption

Article:  On August 27, 2008, the Securities and Exchange Commission (SEC) unanimously agreed on a series of steps that could lead to the required use of international financial reporting standards (IFRS) by U.S. issuers by 2014.
Published on June 10, 2010

Sec. 409A International Issues

Article:  Application of Sec. 409A is not limited to plans maintained in the United States, nor is it necessarily limited to deferred compensation earned for service performed in the United States. Therefore, Sec. 409A can come into play in the case of deferred compensation agreements for either inbound or outbound employees
Published on June 10, 2010

Riding the Estate Planning Roller Coaster for the Next Three Years

Article:  As 2010 approaches, tax legislators and policy makers are sharply divided on a more permanent approach to taxing the transfer of wealth from one generation to the next.
Published on June 10, 2010

New Temp. Regs. Under Sec. 905(c)

Article:  The IRS issued new temporary and proposed regulations under Secs. 905(c) and 6689, which update the 1988 temporary regulations governing a taxpayer’s obligations with respect to a foreign tax redetermination.
Published on June 10, 2010