tax Archive
Tax Court Lacks Jurisdiction in Innocent Spouse Case Pending Before District Court
December 23, 2021
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TweetShareSharePin0 Shares In Coggin v. Commissioner, 157 T.C. No. 12 (2021) the Tax Court issued a precedential opinion interpreting IRC 6015(e)(3) regarding its jurisdiction to hear an innocent spouse case when a district court simultaneously has the same issues pending before it. In her pleadings in district court Ms. Coggin sought a determination that she

Tax Extenders Slated to Expire at End of 2021
December 22, 2021
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TweetShareSharePin0 Shares It’s that time of year when we review which items of the tax code are scheduled to expire or otherwise change in just a few days. An eclectic group of temporary tax policies approach their expiration dates, but at the last minute typically hitchhike onto must-pass legislation for another temporary extension. Not so
Lenders should not report student loans discharged under ARPA
December 22, 2021
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News PROCEDURE & ADMINISTRATION By Paul Bonner Lenders and servicers of most student loans should not file Form 1099-C, Cancellation of Debt, for loans discharged in 2021 through 2025, since borrowers do not have to include these forgiven amounts as income for tax purposes, the IRS stated Tuesday. The guidance in Notice
IRS Correspondence Exams: Doing Less with Less
December 22, 2021
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TweetShareSharePin0 Shares I’m not a huge fan of the suggestion to “do more with less.” To me, it tastes like a corporate-sugar coat to otherwise clearly insipid advice: “be more efficient.” During the pandemic more than ever it should be clear that there are actual bandwidth limitations: sometimes you legitimately need more (time, resources, staff,

TPC’s 2021 Lump Of Coal Award For The Worst Tax Policy Ideas Of The Year
December 22, 2021
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TweetShareSharePin0 Shares Welcome to the Tax Policy Center’s annual Lump of Coal Award for the year’s biggest tax policy blunders, Build Back Better edition. Even by the usual low standards, 2021 saw more than its share of terrible ideas, and worse execution. Here are the Top Ten: 10. A little help on remote work, Supreme
District Court Latest to Find Mailbox Rule Supplanted By Regulations
December 21, 2021
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TweetShareSharePin0 Shares The story is familiar: a taxpayer or their practitioner allegedly mails a refund claim before the statute of limitations has expired. The IRS never receives the claim. The mailing was not done by registered or certified mail, nor by authorized private delivery service. Eventually the taxpayer or their practitioner checks on the supposedly

1% Buyback Tax Could Lead to Higher Dividend Payouts
December 20, 2021
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TweetShareSharePin0 Shares The Build Back Better proposal for a 1 percent excise tax on corporate share buybacks would reduce their tax advantage relative to dividend distributions. Equivalent to a corporate tax rate increase of 0.8 percent on earnings distributed as share repurchases, the new tax would generate about $124 billion over 10 years and could

US Cross-border Tax Changes | OECD Global Minimum Tax Rules
December 20, 2021
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TweetShareSharePin0 Shares As 2021 comes to a close, countries are moving toward harmonizing tax rules for multinationals, but stalled talks on the Build Back Better Act (BBBA) in the United States means new uncertainties for a global agreement and for taxpayers. Despite the 2017 U.S. tax reform serving as inspiration for current discussions of a
SALT payments before year end a priority for passthroughs
December 20, 2021
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TweetShareSharePin0 Shares The IRS’s clarification in 2020 that partnerships and S corporations may deduct their state and local tax (SALT) payments at the entity level in computing their nonseparately stated taxable income or loss was welcomed by taxpayers and their advisers. After all, partners or shareholders might otherwise have to reckon with the Sec. 164(b)(6)
TIGTA Report on EITC Audit Procedures Suggests Room for Improvement in IRS Communication and Education Strategy
December 20, 2021
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TweetShareSharePin0 Shares Today we welcome back guest blogger Anna Gooch. Anna highlights ongoing discussions of the IRS’s communication and education strategy between TIGTA, the IRS, and stakeholder groups. This topic is particularly timely following the President’s executive order on improving customer experience across the federal government, which states in part, that Creatively re-thinking taxpayer communication