tax Archive
The Limits of Community Property Relief When Spouses Split a Joint Business
April 18, 2022
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TweetShareSharePin0 Shares We have not covered IRC 66(c) relief from community property taxation in detail on PT before. Keith wrote about the 2018 case of U.S. v. Kraus, where the grant of personal relief under IRC 66 failed to lift the federal tax lien or prevent foreclosure of the lien. (Similar hurdles exist with IRC

Happy Tax Day | Tax Policy Center
April 18, 2022
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TweetShareSharePin0 Shares The Bidens released their 2021 tax returns. The President and Vice President released their 2021 tax returns last week. President Biden and Jill Biden earned $610,702 in 2021 and paid an effective federal income tax rate of 24.6 percent. Vice President Kamala Harris and husband Doug Emhoff paid an effective rate of 31.6
Dial, redial, repeat
April 15, 2022
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TweetShareSharePin0 Shares We welcome back guest blogger Barbara Heggie. Barb is the supervising attorney for the Low-Income Taxpayer Project of 603 Legal Aid in Concord, New Hampshire. Her clinic serves taxpayers through the Granite State and is the only LITC in the state. Today, she describes a recent experience in trying to assist a client.
Ninth Circuit Reverses Tax Court Interpretation of IRC 6751(b)
April 14, 2022
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TweetShareSharePin0 Shares The question of when a supervisor must give approval for imposition of a penalty has created much litigation in the Tax Court as taxpayers try to remove a penalty proposal by using the failure of the IRS to comply with the IRC 6751(b) approval process. In Laidlaw’s Harley Davidson Sales v. Commissioner, No.

IRS’s FATCA enforcement fell short, TIGTA says
April 13, 2022
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TweetShareSharePin0 Shares When Congress passed the Foreign Account Tax Compliance Act (FATCA) (as part of the Hiring Incentives to Restore Employment Act, P.L. 111-147) in 2010, the Joint Committee on Taxation estimated it would bring in $8.7 billion in revenues in the next 10 years. To that end, the IRS drafted an ambitious, agencywide FATCA

Corporate Tax Revenue and Federal Tax Collections Reach Record High
April 13, 2022
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TweetShareSharePin0 Shares After corporate tax revenue came in at a record high of $372 billion in fiscal year 2021, we have been eagerly awaiting the forecast for fiscal year 2022, which the Congressional Budget Office (CBO) normally publishes in January but now plans for the week of May 23rd. The White House has included a

Personal Income Tax Adjusts for Inflation, But It Could Do Better
April 13, 2022
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TweetShareSharePin0 Shares In times of inflation, like we are experiencing now, a review of the tax code shows that some provisions are automatically indexed, or adjusted, to match inflation, while others are not. And that creates unfair burdens for taxpayers. But it’s not always as simple as just “adjusting for inflation.” That works for some

More Schedule K-2 and K-3 FAQs posted
April 13, 2022
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News PARTNERS & PARTNERSHIPS By Paul Bonner The IRS has added eight new questions and answers to its website’s frequently asked questions (FAQs) on Schedules K-2 and K-3, clarifying that affected partnerships and S corporations need complete only the forms’ relevant portions and addressing an array of special circumstances. The new material
APA and FBAR Skirmishes Continue in Schwarzbaum v US
April 13, 2022
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TweetShareSharePin0 Shares A couple of months ago in 11th Circuit Remands Willful FBAR Penalty Case Back to IRS Due to APA Violation I blogged about Schwarzbaum v United States, where the Eleventh Circuit held that Schwarzbaum willfully violated his FBAR reporting obligations for three years but that the IRS miscalculated the FBAR penalties. As I discussed,

The Surprising Regressivity of Grocery Tax Exemptions
April 13, 2022
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TweetShareSharePin0 Shares Key Findings Exempting groceries from the sales tax base reduces economic efficiency without achieving its objective of enhancing tax progressivity. The poorest decile of households experiences 9 percent more sales tax liability with a grocery tax exemption than they would if groceries were taxed and the general rate were reduced commensurately. Grocery tax