Could Forgetting to Include the Effect of UNICAP Put Accounting Method Changes at Risk

Article:  Taxpayers making automatic accounting method changes that affect capitalizable costs should consider the uniform capitalization rules of Sec. 263A and the related regulations (UNICAP rules).
Published on April 27, 2012

IRS Issues Final Regs. and Guidance on Mandatory E-Filing Requirements

Article:  The IRS issued final regulations and several pieces of guidance relating to the requirement that return preparers e-file tax returns, starting this year. The final regulations require specified tax return preparers to e-file if they reasonably expect to file 100 or more income tax returns in 2011.
Published on October 04, 2011

Lack of Control Does Not Except Owners from Trust Fund Recovery Penalty

Article:  The owners of a company who had delegated payroll functions to a separate payroll company they owned but did not operate were liable for trust fund recovery penalties because they were responsible persons both before and after the withholding taxes that were the basis of the penalties accrued.
Published on October 04, 2011

Expanded 1099 Reporting Requirements Repealed

Article:  The Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 repeals both the expanded Form 1099 information reporting requirements mandated by last year’s health care legislation and also the 1099 reporting requirements imposed on taxpayers who receive rental income enacted as part of last year’s Small
Published on October 04, 2011

100% Bonus Depreciation Guidance Issued

Article:  In Rev. Proc. 2011-26, the IRS has issued guidance on how taxpayers can deduct 100% of the cost of qualified business property placed in service in 2011 under rules enacted last year .
Published on October 04, 2011

Expense Does Not Qualify as Compensation but Does Qualify as Theft Loss

Article:  The Tax Court held that amounts that an abusive man took from his live-in girlfriend’s business did not qualify as deductible compensation expenses but did qualify as deductible theft losses.
Published on October 04, 2011

Guidance on Unbundling Trustee Fees Extended

Article:  The IRS announced that it is extending interim guidance on the treatment of investment advisory fees and other costs subject to the 2% floor under Sec. 67(a).
Published on October 04, 2011

IRS Issues Guidance on Treatment of Gift Cards

Article:  This item provides background information on the tax and accounting treatment of gift card income and discusses two revenue procedures that address these issues.
Published on October 04, 2011

IRS Allows Oil and Gas Company a Bulk Sale Exception

Article:  A recent IRS letter ruling provides helpful insights to independent producers of oil and gas that, by claiming allowable percentage depletion deductions, can lower their costs, while at the same time securing contracts for bulk sales of oil and gas with industrial, commercial, and government entities.
Published on October 04, 2011

Sales-Based Royalties and Vendor Allowances

Article:  Proposed regulations would allocate sales-based royalties and vendor allowances to property sold during the tax year. The preamble indicates that the intention of the proposed regulations is that neither sales-based royalties nor sales-based vendor allowances should adjust the value of ending inventories.
Published on October 04, 2011

Building Value Through Sustainability

Article:  The authors describe a company that formed a sustainability committee in 2008 to monitor the various initiatives taking place around five pillars identified as important to the firm: people, clients, community, profession, and environment.
Published on October 04, 2011

Foreign Disregarded Entities May Face U.S. FICA Tax Issue

Article:  This item shows how restructuring international businesses to operate through entities disregarded for U.S. federal income tax purposes may also affect the employment tax treatment of the organization’s individual employees.
Published on October 04, 2011

Engagement Letter Fairness Opinion Fee Language May Affect Fees Taxation

Article:  Language used in investment banker (IB) engagement letters to implement fee payment arrangements can significantly affect the federal income tax treatment of such payments.
Published on October 04, 2011

Telecom Universal Service Fund Payments Not Excludible from Income Under Sec. 118

Article:  Governments sometimes make payments to telecommunications carriers for providing telephone and communication services to low-income users and those in remote or isolated areas. The courts have recently addressed the tax treatment of those payments.
Published on October 04, 2011

Individual Taxation Digest of Recent Developments

Article:  This article covers recent developments affecting taxation of individuals, including last year’s tax relief and small business legislation, regulations, cases, and IRS guidance. The items are arranged in Code section order.
Published on October 04, 2011