Notes From the July IRS Stakeholder Liaison Meeting

The following is a compilation of the presentations given at the last IRS Stakeholder liaison meeting as prepared by IRS Senior Stakeholder Liaison Debra Rodgers complete with some very pointed questions and answers. Please pay particular attention to Nancy Carver's

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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, IRS Transcript

Transfers of Property to a Corporation Internal Revenue Code Section 351

According to IRC 1001 you generally recognize a gain or a loss when you sell or dispose of property. However, there are a number of exceptions, specifically transfers of property to a corporation. For example under IRC 351a no gain

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Posted in Basis, Capital Gain, Capital Loss, Self Employ, Small Business, Sub-chapter S, Tax Guidance & Preparation

Traders in Securities

If you are an individual who buys and sells securities you may qualify as a “trader in securities,” for tax purposes. This post attempts to explain how traders must report the income and expenses from being in the trading business.

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Posted in Accounting Method, Business Expense, Capital Gain, Capital Loss, Cost Basis, Investment Income, Mark to Market, Paying Taxes, Self Employ, Tax Guidance & Preparation

Income Tax Filing Status for Same Sex Married Couples

The following states recognize same sex marriages:  Connecticut, Delaware, Iowa, Maine, Maryland, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont, Washington, and District of Columbia.  In the most recent Supreme Court decisions that I blogged about earlier a great deal

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Posted in Filing Status

US Supreme Court DOMA Throw Down – Progress or Kabuki Theater?

The fact of the matter is that the IRS will continue to define marriage for US Taxpayers everywhere in that only one man and one woman married to each other can file an income tax return with the filing status

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Posted in Filing Status, Marriage

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
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