The draft proposal would require identification of up to three Internal Revenue Code sections which relate to the position. Some commentators have suggested it might be a good idea to disclose additional code sections in the description of the position to avoid later assertions of...
As set forth in the draft instructions, the initial disclosure with respect to the 2010 tax year would be required from corporations that have uncertain tax positions own assets exceeding $10 million issue audited financial statements, and are required to file a Form 1120, 1120L, 1120PC or 1120F. It...
As set forth in the current drafts, an uncertain tax position includes a federal income tax position for which the taxpayer has recorded a reserve in an audited financial statement. It also includes a position where no reserve is reported either due to an asserted...
Videos HIRE Act: English Small Business Health Care Tax Credit: English WASHINGTON — In recognition of National Small Business Week, the Internal Revenue Service encourages small businesses to take advantage of tax-saving opportunities included in recently enacted federal legislation. A variety of business tax deductions and credits...
HIRE and Section 179 Deduction - A qualifying taxpayer can choose to treat the cost of certain property as an expense and deduct it in the year the property is placed in service instead of depreciating it over several years. This property is frequently referred...
As part of the IRS's continuing efforts to require greater disclosure of tax positions and strategies on returns, it recently released new, mandatory disclosure rules for grouping passive activities. Rev. Proc. 2010-13 for the first time mandates that passive-activity groupings and regrouping, as required under...
The American Jobs and Tax Loopholes Act, currently in Congress, would subject to Self Employment Taxes (FICA, FUTA, SUTA) all distributions from S Corporations which are "personal service" corporations. This is HUGE. This is not good for the small business owner. If...
New York Times, Whistle-Blowers Become Investment Option for Hedge Funds, by David Kocieniewski: Hedge funds have found a new market to invest in: whistle-blowers. Informants who turn in tax cheats have to wait years to get their share of any reward from the IRS’s recently...
The Treasury Department released new guidelines for applying for tax credits to fund promising new therapies, with small medical research firms eligible to receive up to $5 million each out of a $1 billion pie. The Therapeutic Discovery Credit was established as part of the health...
Question: Tax payer produced Form 1099-S from the sale of property she owned jointly with her brother. The Form 1099-S had the full amount reported to her and the brother did not receive a Form 1099-S. What should be done? Answer: The IRS explains in the...