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tax Advice Archive

Tax treatment of COVID-19 homeowner relief payments clarified

TweetShareSharePin0 Shares Homeowners who receive or benefit from payments from a federal homeowner assistance fund were given an optional IRS safe harbor Monday for computing their itemized deductions for mortgage interest and real property taxes. The guidance, in Rev. Proc. 2021-47, is intended to allow taxpayers to compute their itemized deductions for mortgage interest and

Passport Revocation Cases Part 1

TweetShareSharePin0 Shares We are in the process of the three times a year exercise of updating the Saltzman and Book treatise “IRS Practice and Procedure.”  As we have mentioned previously, the blog started primarily because we must stay on top of procedural cases in order to update the treatise.  Sometimes the blogging of cases informs

Infrastructure bill tax provisions include ERC termination

TweetShareSharePin0 Shares The employee retention credit will be terminated early and broker reporting of cryptoasset transfers will be required as a result of legislation (H.R. 3684) that passed the House of Representatives late Friday and is headed to President Joe Biden’s desk to be signed into law. Known as the Infrastructure Investment and Jobs Act,

IRS makes retirement account inflation adjustments for 2022

TweetShareSharePin0 Shares News EMPLOYEE BENEFITS & PENSIONS By Paul Bonner This IRS issued Notice 2021-61 Thursday updating for 2022 dollar-amount ceilings and thresholds for a wide range of qualified retirement plans and accounts, including traditional individual retirement arrangements (IRAs) and Roth IRAs. The notice also has the 2022 limits on elective deferrals for plans

IRS Succeeds in Jurisdictional Argument – With a Twist

TweetShareSharePin0 Shares For years the IRS has argued against the application of the Supreme Court’s jurisprudence regarding time periods for filing cases.  It has consistently taken the position that time periods for filing are jurisdictional in order to keep taxpayers to whom it gave the wrong dates for filing, who never received notices, who were

Carried interest reporting FAQs and guidance posted

TweetShareSharePin0 Shares In News Release IR-2021-215 and a webpage answering frequently asked questions (FAQs), the IRS provided guidance Wednesday on filing and reporting by passthrough entities and holders of applicable partnership interests (APIs) held in connection with performance of services under Sec. 1061, known as carried interests. The FAQs provide further guidance on final regulations

Some Notes on Economic Reality and Section 7602(e)

TweetShareSharePin0 Shares We welcome back Bob Kamman who writes today about the past and how it matters in having a full understanding of the current debate forbidding the use of financial status or economic reality examination techniques.  Like Bob, I remember when the IRS rolled out economic audits.  His remembrances and insights help inform the
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