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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

Comparing Corporate Tax Systems in Europe, 2021

TweetShareSharePin0 Shares On October 17, we released the International Tax Competitiveness Index 2021, a study that measures and compares the competitiveness and neutrality of all 37 OECD countries’ tax systems. In the coming weeks, we will illustrate how European OECD countries rank in each of the five components of the Index: corporate income taxes, individual

It Would Be a Mistake to Resurrect Corporate Alternative Minimum Tax

TweetShareSharePin0 Shares The latest version of the Biden administration’s Build Back Better reconciliation package reintroduces a policy that has been tried before—and abandoned: a corporate alternative minimum tax (AMT). It would be a mistake to revive this complex and poorly designed policy. Instead, lawmakers should consider directly reducing corporate tax expenditures. The corporate alternative minimum tax was

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

Will the Ohio Supreme Court Fuel the State’s NASCAR Tax?

TweetShareSharePin0 Shares “If you ain’t first, you’re last.” That all-or-nothing motto catalyzes number one NASCAR driver and titular hero in the 2006 spoof, Talladega Nights: The Ballad of Ricky Bobby.  Funny coincidence: My kids and I watched the movie on television right after I read about NASCAR’s (National Association for Stock Car Auto Racing Holdings,

Recent Developments in Partnership Audits (Part 2)

TweetShareSharePin0 Shares In yesterday’s post Rochelle Hodes, Principal with Crowe LLP, provided background on BBA, emphasizing what makes its rules unique in tax procedure. Today’s post will briefly discuss two important BBA developments, the IRS’s Large Partnership Compliance Program and significant ABA Tax Section comments on proposed BBA regulations. Les The IRS is scheduled to
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