Category Archives: Featured on Homepage

IRS Finalizes Regs Removing Requirement To File Code Sec. 83(b) Election With Return

Final regs have been issued that remove the requirement that a taxpayer making a Code Sec. 83(b) election file a copy of the election with the taxpayer’s return for the year of the Code Sec. 83 transfer. The final regs track proposed regs issued … Continue reading


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Reduced Exclusion Available To Couple Who Sold Residence After Birth Of Second Child

A married couple could take advantage of the reduced maximum exclusion of gain from the sale of their home after the birth of their second child, the IRS has determined. Unforeseen circumstances were the primary reason for the sale and … Continue reading


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Offshore Trusts Were Used To Commit Tax Fraud, Bankruptcy Court Finds

A federal bankruptcy court has found that a taxpayer used offshore trusts to hide some $1 billion from U.S. taxation. The court was not persuaded that the taxpayer had used the offshore trusts for tax deferral, as he claimed, rather … Continue reading


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IRS Announces Acquiescence In Per Taxpayer Mortgage Deduction Ruling

The Ninth Circuit Court of Appeals, reversing the Tax Court, had found that when multiple unmarried taxpayers co-own a qualifying residence, the debt limit provisions apply per taxpayer and not per residence.


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IRS Issues Regs To Require Unreported Foreign-Owned Disregarded Entities To Disclose Ownership Through EINs/Information Returns

The IRS has issued proposed regs that would impose new reporting requirements on U.S. disregarded entities (DEs) solely owned by a foreign party. The IRS stated that, under current law, these DEs and their foreign owners are unknown because they … Continue reading


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Taxpayer Not Required To File FBAR For Offshore Online Gambling Accounts; Accounts Were Not Banks

The Ninth Circuit Court of Appeals has held that a taxpayer was not required to file a Foreign Bank and Financial Account Report (FBAR) with respect to two online gambling accounts established in foreign countries used only to play poker … Continue reading


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Tax Court Denies Conservation Deduction; Easement Not Protected In Perpetuity

With the increased popularity and scrutiny of Conservation Easements, we thought it would be of interest to outline a recent tax court decision.  In a case of first impression, the Tax Court has found that a conservation agreement violated the … Continue reading


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IRS Unveils Procedures For Expensing, Bonus Depreciation And More Under PATH Act

The IRS has released guidance related to Code Sec. 179 expensing, bonus depreciation and other related changes in the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The guidance describes the procedures for filing amended returns and taking other actions.


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Late Breaking Tax Letter

Many individuals and businesses involved in year-end tax planning are trying to predict the tax changes that may occur after 2016, with the election of Donald Trump as the 45th President of the United States.  During his campaign, Mr. Trump … Continue reading


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2016 New Tax Developments

  As 2016 comes to an end, we thought it would be beneficial to provide an overview of the new developments in US tax law. This overview includes the items we believe are most relevant for the year and is … Continue reading


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