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Tax Articles

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 receives boot from the corporation your basis must be decreased by the amount of any…


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 of any taxable gain on the transaction. For example if you transfer computer programs and…


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 generally speaking subject of course to certain thresholds no gain (or loss) is recognized for…


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 Agreement Program (APMA) Alien Alien Taxation Alien, Departure Permit Alien, Dual-status Alien, Nonresident Alien, Resident…


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 those sentenced both gained roughly 12 percent (2,634) from 2011.  The Service was able to…


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 takes a carrot-and-stick approach as credits are offered for those who need financial help with…


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, almost 81 percent were e-filed. More than 120 million individual income tax return filers received…


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 acted to regulate persons who represented citizens in their dealings with the U.S. Treasury Department. …


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 Force, Navy, Marine Corps and Coast Guard Military-based Voluntary Income Tax Assistance (VITA) sites staffed…


IRS Form 7004 Automatic Extension of Time To File Certain Business Income Tax, Information, and Other Returns.

If your corporation, partnership or estate operates on a calendar year basis the tax return is due March 15th which is coming up! If you need additional time to file tax returns for these entities file IRS Form 7004 which is an application for Automatic Extension of Time To File Certain Business Income Tax, Information, and Other…