tax Archive

Formulary Apportionment and the OECD Tax Deal

TweetShareSharePin0 Shares One of the greatest challenges of lawmaking is recognizing when a beautiful theory must succumb to an ugly fact. The purity of conceptual policymaking must take the real world into account and acknowledge that things that work well “in theory” sometimes fail spectacularly to meet expectations “in practice.” It would be wonderful if

Honest Mistakes Happen, But a Two Million Dollar Difference in Mortgage Interest Will Likely Trigger An Accuracy-Related Penalty

TweetShareSharePin0 Shares Busch v Commissioner, a small tax case issued as a bench opinion, involves a couple who claimed to have made an honest mistake on their self-prepared tax return.  According to the Busches, when using their tax return prep software, the software did not allow them to enter cents when recording the mortgage interest

AICPA again asks IRS to delay K-2/K-3 reporting

TweetShareSharePin0 Shares The AICPA and 52 state and area CPA societies submitted further comments and concerns to the IRS and Treasury on Friday urging a delay until next year of required reporting by partnerships and S corporations of items of international tax relevance on new Schedules K-2, Partners’ Distributive Share Items — International, and K-3,

The Taxpayer First Act’s Legacy: What Comes Next

TweetShareSharePin0 Shares For the last few years, I’ve asked my students whether they’ve heard of the “Tax Cuts and Jobs Act” before. Many raise their hand. Because I’m insufferable, my first order of business is to tell them that there is really no such thing as the “Tax Cuts and Jobs Act” (or TCJA). What

How Did We Get Here? 2-D Barcoding and the Paper Return Backlog – A Missed Opportunity

TweetShareSharePin0 Shares In her February 17, 2022 testimony before the Senate Finance Committee, the National Taxpayer Advocate reported that as of February 5, 2022, the IRS had 23.5 million returns and correspondence in its inventory requiring manual processing.  This number includes 17.6 million original and amended individual and business returns, down from the 35.5 million

Proposed regulations update RMDs for SECURE Act changes

TweetShareSharePin0 Shares The IRS and Treasury released proposed regulations Wednesday (REG-105954-20) that would update existing rules for required minimum distributions (RMDs) from qualified retirement plans and annuity contracts and related matters, largely to conform with a number of statutory changes. The most prominent and recent of these changes were made by the Setting Every Community

How Did We Get Here? A New Series …

TweetShareSharePin0 Shares These days, the news has been filled with stories about the disastrous state of the IRS this filing season and how this is attributable, in part if not in entirety, to underfunding of the IRS over the last decade.  Now, I agree the IRS needs more funding to accomplish its dual mission of

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