Tax Treatment of IRC 351 Nonrecognition Transactions aka Corporate Reorganizations

Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also

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Posted in 1031 Exchange, 1231 Exchange, Basis, Capital Gain, Capital Loss, Like/Kind Exchange, Sub-chapter S, Uncertain Tax Position

Tax Treatment of Liabilities Assumed by a Corporation IRC 357 – What is Boot?

According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount

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Posted in Abusive Tax Shelter, Basis, Boot, Capital Gain, Capital Loss, Cash Transaction, Deductible Expense, Distributions, Tax Guidance & Preparation

Requirements for Nonrecognition of Gain (or Loss) on Transfer of Property to a Corporation IRC 351

If property is transferred to a corporation by one or more people solely in exchange for stock in the corporation and immediately after the exchange the person or people engaged in the exchange are in control of the corporation then

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Posted in 351, Capital Gain, Capital Loss, Corporation, Like/Kind Exchange, Tax Guidance & Preparation

Online Tool for Taxpayers with International Tax Filing Requirements

A new online tool has been created by the IRS for taxpayers with international tax filing requirements that is worth checking out.  Here are some relevant links: A Acceptance Agents Accountable Plans Advance Pricing Agreement (APA) Advance Pricing and Mutual

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Posted in International Tax

IRS Criminal Investigation Annual Report

IRS Criminal Investigation (CI) released its Annual Report for fiscal 2012. Investigations initiated (5,125) and prosecution recommendations were both up in fiscal 2012 compared to the prior year. Filings of indictments and other charging documents rose 13 percent. Meanwhile, convictions and

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Posted in Charitable Contribution, IRS Criminal Enforcement, IRS Enforcement, Tax Abuse

ObamaCare’s Health Insurance Premium Tax Credit Proposed Regulations

The Affordable Care Act or ObamaCare was passed almost three years ago with the goal of extending quality health insurance coverage to more Americans and it becomes fully effective January 1st 2014. To encourage compliance, the Act for all intents and purposes

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Posted in Affordable Care Act, Health Care Tax Credit, Health Insurance, ObamaCare

Disaster Losses Including Casualty and Theft IRS Publication 547 – IRS Form 4684

If you take one look at FEMA’s website, it’s clear that we are going to see a significant increase in the number of casualty losses going forward. Should you find yourself a victim of a disaster or a casualty or theft loss it is

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Posted in Casualty Loss, Disaster Loss, Theft Loss

It has been QUITE a tax season! A Review of IRS Activity

According to the newly released 2012 IRS Data Book, the IRS collected almost $2.5 trillion in federal revenue and processed 237 million returns, of which almost 145 million were filed electronically. Out of the 146 million individual income tax returns filed,

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Posted in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, Tax Court, Tax Fraud, Tax Guidance & Preparation

What is an Enrolled Agent (EA) and Why is this Designation Superior to Certified Public Accountant (CPA)

The Enrolled Agent (EA) is arguably the longest standing professional tax designation.  Although at times overshadowed by other tax professionals EA’s are the only federally licensed tax practitioners who specialize in taxation. The EA was established in 1884 when Congress

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Posted in Enrolled Agent

IRS Publication 3 – Armed Forces Tax Guide

According to IRS Publication 3, Armed Forces’ Tax Guide, the Armed Forces Tax Council (AFTC) oversees the military tax programs offered worldwide. AFTC partners with the IRS to conduct outreach to military personnel and their families. This includes the Army, Air

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Posted in Earned Income Tax Credit, Military Personnel Tax, Tax Guidance & Preparation, VITA
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