IMPACT ON TAXPAYERS The Internal Revenue Service (IRS) protects its claims against taxpayers who owe delinquent taxes by filing Federal Tax Liens (liens), which establishes the IRS’ priority among secured creditors for the taxpayers’ equity. However, lien determinations were not appropriately made or were made late...
The Seventh Circuit Court of Appeals ruled yesterday that the Internal Revenue Service can still apply a two-year deadline to taxpayers looking to file for "innocent spouse" relief. The court reversed a previous Tax Court ruling, which held that because the statute did not specify a...
The draft proposal would require identification of up to three Internal Revenue Code sections which relate to the position. Some commentators have suggested it might be a good idea to disclose additional code sections in the description of the position to avoid later assertions of...
As set forth in the draft instructions, the initial disclosure with respect to the 2010 tax year would be required from corporations that have uncertain tax positions own assets exceeding $10 million issue audited financial statements, and are required to file a Form 1120, 1120L, 1120PC or 1120F. It...
As set forth in the current drafts, an uncertain tax position includes a federal income tax position for which the taxpayer has recorded a reserve in an audited financial statement. It also includes a position where no reserve is reported either due to an asserted...
Videos HIRE Act: English Small Business Health Care Tax Credit: English WASHINGTON — In recognition of National Small Business Week, the Internal Revenue Service encourages small businesses to take advantage of tax-saving opportunities included in recently enacted federal legislation. A variety of business tax deductions and credits...
HIRE and Section 179 Deduction - A qualifying taxpayer can choose to treat the cost of certain property as an expense and deduct it in the year the property is placed in service instead of depreciating it over several years. This property is frequently referred...
As part of the IRS's continuing efforts to require greater disclosure of tax positions and strategies on returns, it recently released new, mandatory disclosure rules for grouping passive activities. Rev. Proc. 2010-13 for the first time mandates that passive-activity groupings and regrouping, as required under...
The American Jobs and Tax Loopholes Act, currently in Congress, would subject to Self Employment Taxes (FICA, FUTA, SUTA) all distributions from S Corporations which are "personal service" corporations. This is HUGE. This is not good for the small business owner. If...
New York Times, Whistle-Blowers Become Investment Option for Hedge Funds, by David Kocieniewski: Hedge funds have found a new market to invest in: whistle-blowers. Informants who turn in tax cheats have to wait years to get their share of any reward from the IRS’s recently...