Practical perspectives for contemporary legal challenges.
The IRS has recently began sending letters to certain owners of virtual currency (e.g., Bitcoin, Ether, etc.) regarding requirements for reporting transactions involving such virtual currencies. See IRS Information Release 2019-132. The IRS is concerned that taxpayers have been entering into virtual currency transactions and failing to properly report them. The letters are an offshoot …
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IRC § 1400Z-2, under The Tax Cuts and Jobs Act of 2017, established an investment program designed to provide preferential tax treatment for investment in developments located within certain designated economically distressed communities known as “Opportunity Zones”. All 50 states, the District of Columbia, and each of the five U.S. territories, have Opportunity Zones within …
As the renewable energy industry continues to grow and alternative forms of clean energy (wind, solar, hydro, geothermal, biomass, etc.) proliferate nationwide, state lawmakers are more than ever discussing comprehensive approaches to energy policy. Indeed, states across the country are rapidly reconsidering the diverse array of laws that impact energy developers / public utilities, including …
According to statements made by the acting director of exempt organizations at the IRS, churches and other religious organizations will soon start to receive questions from the IRS about potential liabilities under the Affordable Care Act. Over the last few years, the IRS has sent letters to employers that it suspects have failed to comply …
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Has a client decided to leave their bank account or entire estate to one of their children, who will “do the right thing, and distribute it equally among all of my children”? Discuss with your client that this scenario creates 2 problems: 1) Child receiving the account/inheritance is not legally obligated to give any of …
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The Generation-Skipping Transfer (“GST”) tax is designed to prevent taxpayers from avoiding estate tax on a child’s inheritance at the child’s death by “skipping” inheritances over children to grandchildren. Each person currently has a lifetime GST exemption amount of $11,400,000 (in 2019, and indexed for inflation). If you make a transfer during lifetime or at …
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The length of time you should keep tax records depends on the action, expense, or event which the records will substantiate. Generally, you should keep records until the statute of limitations period for an audit or assessment of that tax return expires: 3 YEARS from the date you filed your original return or 2 years …
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The IRS recently issued a Chief Counsel Memorandum clarifying when a family member of a 2% shareholder in an S corporation is entitled to a deduction under Section 162(l) of the Internal Revenue Code (the “Code”) for health plan insurance premiums paid for coverage provided to the family member by the S corporation. Chief Counsel …
Certain qualified retirement plan errors are now easier to fix under the new expanded IRS self-correction procedures. On April 19, 2019, the IRS released the revised Employee Plans Compliance Resolution System (“EPCRS”) under Revenue Procedure 2019-9. EPCRS allows employers of all sizes to identify and correct retirement plan errors under the Self-Correction Program (“SCP”), Voluntary …
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Like the poor little bird in the Dr. Seuss book that struggled to identify its mother, it can sometimes prove difficult for partners in a partnership to identify their partners for federal income tax purposes. Partnerships for tax purposes include general partnerships, limited partnerships and limited liability companies taxed as partnerships. The federal income tax …