Group of airline pilots fighting FICA taxes paid on non-deferred compensation benefits have case dismissed for failure to follow court orders to submit short-form complaint, the Court of Federal Claims ... Read More
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Where the extended six-year assessment period under tax code Section 6501(e)(1)(C) applies as a result of omitted subpart F income, the extended assessment period applies to the entire return ... Read More
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Issuance of a Letter 627, Estate Tax Closing Letter, to an estate does not preclude the IRS from examining the return, the Chief Counsel’s Office informally advised. The IRS ... Read More
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A case involving potential “Westbrooks” limitations on IRS assessment and collection of restitution imposed as a condition of a period of supervised release is not a Westbrooks case, the Chief ... Read More
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A case in which a defendant was convicted solely of Title 26 (tax code) crimes after pleading not guilty is subject to “Westbrooks” limitations on IRS assessment and collection of ... Read More
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Two cases involving false return preparation and potential “Westbrooks” limitations on IRS assessment and collection of restitution imposed as a condition of a period of supervised release are not Westbrooks ... Read More
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Rehires following bona fide retirement and in-service distributions frequently asked questions posted to IRS website October 22. If an employee who has a bona fide retirement and begins benefit distributions ... Read More
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The IRS October 22 released Internal Revenue Bulletin 2021-43, dated October 25, 2021, containing the following previously released items: Notice 2021-58 (COBRA continuation coverage) and Notice 2021-59 (foreign currency regulations ... Read More
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Draft Form 7203, S Corporation Shareholder Stock and Debt Basis Limitations, released October 21 to be used in figuring a shareholder’s stock and debt basis which replaces a three-part ... Read More
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Employers reminded that they generally will not jeopardize the tax status of their pension plans if they rehire retirees or permit distributions of retirement benefits to current employees who have ... Read More
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Families, teens and senior citizens reminded about the continued importance of protecting personal and financial information online despite the IRS and its Security Summit partners continuing to make strides in ... Read More
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Public comments released October 22 on Notice 2021-56 providing standards that a limited liability company (LLC) must satisfy to receive a determination letter recognizing it as tax-exempt under tax code ... Read More
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A consolidated group parent that experienced an ownership change received extra time to elect under Treasury Regulations Section 1.382-6(b) to allocate its net operating loss or taxable income and ... Read More
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A corporate group parent operating in multiple currencies may change its spot rate convention to the method it proposed for computing monthly exchange gain or loss with respect to payables ... Read More
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An electric and natural gas utility is not permitted under the normalization rules of tax code Section 168(i)(9), former Section 167(l), and Tax Cuts and Jobs Act (Pub. ... Read More
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A partnership received extra time to make an election under tax code Section 856(c)(1) to be treated as a real estate investment trust (REIT) for a certain tax year, ... Read More
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The ineffectiveness of a small business corporation’s (“X”) S election, caused by its having an ineligible shareholder — a trust for which no electing small business trust (ESBT) election was ... Read More
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The termination of a small business corporation’s (“Company”) subchapter S classification election as a result of its signing an operating agreement that included partnership-contemplating provisions (thus creating an impermissible second ... Read More
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Grant making program to award scholarships annually to graduating high school seniors that are children of employees of B and C stores approved. The grant program will meet the requirements ... Read More
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Grant making program to award scholarship to an entire elementary third -grade class selected due to being in underserved neighborhood and obtaining a specific percentage of students receiving free or ... Read More
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Any “Company X” stock that a public charity receives from a trust pursuant to an agreement with a private foundation and the terms of a decedent’s will won’t be treated ... Read More
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Guidelines and general requirements for the development, printing, and approval of the 2021 substitute tax forms, the IRS provided October 22. The forms covered are: (1) IRS tax forms and ... Read More
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AICPA October 22 publicly released comments supporting S. 2583, the Disaster Retirement Savings Act, that would permanently remove financial penalties for individuals impacted by natural disasters who choose to use ... Read More
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