Individual Taxation Filing Season Update
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This article covers recent significant developments affecting taxation of individuals, including cases, regulations, and legislative changes, and important information for the upcoming filing season.
Published on April 21, 2010
IRS Changes Policy for Asserting Penalties for Late-Filed Form 5471
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The IRS recently sent letters to certain corporate taxpayers advising them that effective January 1, 2009, penalties for late-filed Forms 5471 will automatically be asserted when such forms are attached to a late-filed Form 1120.
Published on April 19, 2010
Tread Carefully What CPAs Should Know About Tax Fraud
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This article examines Sec. 6663 and the civil tax fraud penalty it imposes.
Published on April 19, 2010
Limitations on Taxpayers Ability to Disavow Tax Consequences of Contract Terms
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The circuit courts have split on the issue of when a taxpayer should be able to disavow the form of his or her transaction and assert that the substance of the transaction controls.
Published on April 19, 2010
LMSB Inspection of Corporate Officers Returns IRM Procedure vs. Actual Practice
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When the IRS’s Large and Mid-size Business (LMSB) Division issues an initial information document request (IDR) to a corporate taxpayer, one topic that corporate officers are often concerned about is the inspection of their individual income tax returns.
Published on April 19, 2010
IRS Automated Underreporter Initiative
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The IRS recently started a “soft notice” initiative and has sent notices to taxpayers to spur voluntary compliance.
Published on April 19, 2010
Communicating with Clients in Difficult Times
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The trusted, knowledgeable adviser must be proactive. Clients trust their CPAs and the advice, information, and education they provide.
Published on April 19, 2010
Questions to Include in Individual Tax Organizers
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To help clients avoid possible penalties and sanctions, practitioners should ensure that the following questions are included in their customized tax software organizers for individual clients for the upcoming filing season.
Published on April 19, 2010
Wrongful Levy Judgment Treated as Overpayment of Tax
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The Ninth Circuit held that for purposes of calculating the overpayment interest rate on a wrongful levy judgment, the judgment should be treated as an overpayment of tax.
Published on April 19, 2010
IRS Identifies Sale of Charitable Remainder Trust Interests as a Transaction of Interest
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In a notice, the IRS has identified as transactions of interest certain transactions in which a sale or other disposition of all interests in a charitable remainder trust (CRT), after the contribution of appreciated assets to and their reinvestment by the trust, results in the grantor (or other noncharitable recipient)
Published on April 19, 2010
Understanding the Effects of Nonliquidating Distributions on Corporations
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Nonliquidating corporate distributions are distributions of cash and/or property by a continuing corporation to its shareholders. At the shareholder level, a nonliquidating corporate distribution can produce a variety of tax consequences, including taxable dividend treatment, capital gain or loss, or a reduction in stock basis.
Published on April 19, 2010
Significant Recent Corporate Developments
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This article summarizes selected U.S. federal income tax developments during 2008 affecting corporations, including those filing consolidated returns.
Published on April 19, 2010
Cancellation of Indebtedness
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The IRS has issued final, temporary, and proposed regulations regarding information returns for cancellation of indebtedness by certain entities.
Published on April 19, 2010
Court Rejects Patentability of Business Methods
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The Federal Circuit has significantly altered the landscape of business method patents by holding that to be patentable a business process must meet the “machine or transformation” test.
Published on April 19, 2010
Volunteer Board President Responsible Person for Payroll Taxes
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Taxpayer who served (without compensation) as the president of a daycare center was responsible person under Sec. 6672.
Published on April 19, 2010