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Federal Taxation

  • IRS Can Resume Charging PTIN User Fees—But Final Cost Still to Be Determined

    By:
    Frank G. Colella, Esq., LL.M, CPA
    |
    Jun 1, 2019

    According to the IRS 26 C.F.R. § 1.6109-2(d), “Beginning after December 31, 2010, all tax return preparers must have a preparer tax identification number or other prescribed identifying number that was applied for and received at the time and in the manner, including the payment of a user fee, as may be prescribed by the Internal Revenue Service.” However, since June 2017, the IRS has suspended this fee charged for a “practitioner tax identification number” or PTIN.

  • Tax Accounting Method + Form 3115 + Under $25 Million

    By:
    Eric P. Wallace, CPA
    |
    May 1, 2019

    Tax accounting methods, and the ability to change those methods, are key issues for taxpayers.  Proper tax accounting methods, and continuing IRS changes to their method-change procedures, are at the front and center of all IRS audits. Tax accounting methods and their change procedures certainly have heightened awareness and importance to tax practitioners; and this is the rule yet again for this tax year.

  • IRS Issues New Guidance for Offshore Voluntary Disclosures

    By:
    Michael Sardar, Esq.
    |
    Apr 1, 2019
    On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners were anxious for the IRS to announce a new program to take its place.

  • Structuring a Transaction: Ways to Minimize Income Tax Implications for Sellers

    By:
    Lisa M. Cribben, CPA/ABV, ASA, CMA and Crystal Christenson, CPA, MST
    |
    Mar 1, 2019

    Most taxable sale transactions are typically structured in one of three ways: asset sale, stock sale, or stock sale with a Sec. 338(h)(10) election. Each of these structures provides certain advantages to the buyer or seller. Below we’ll discuss the nuances of each structure and the importance of the allocation of the sales price. 

  • Medtronic v. Commissioner: New Direction for Transfer Pricing Cases?

    By:
    Rita Chung, CPA
    |
    Jan 1, 2019
    For tax years 2005 and 2006, the IRS proposed a transfer pricing adjustment resulting in a tax deficiency of over $1.35 billion.  Medtronic filed a lawsuit in the U.S. Tax Court, and in June of 2016, the Tax Court issued its decision disagreeing with the IRS’s allocation of income.  

  • Altera: Legislative Intent Within Administrative Bounds

    By:
    Michael I. Billet, JD, CPA
    |
    Oct 1, 2018

    Altera Corporation & Subsidiaries (Altera Corp.) is battling the IRS in court over the validity of a federal income tax regulation that concerns Section 482 of the Internal Revenue Code (IRC).  

  • A Forensic Guide to Finding Cryptocurrency in Divorce Litigation

    By:
    Mark DiMichael, CPA, CFF, ABV, CFE and Katerina Gaebel, CPA
    |
    Sep 1, 2018
    In recent years, awareness and use of Bitcoin and cryptocurrency has risen dramatically. Cryptocurrency transactions are fast, global, decentralized, secure, and irreversible. Although cryptocurrency and blockchain technology have the ability to revolutionize commerce, cryptocurrency’s anonymous nature has made it a haven for illicit activity.  This is because while cryptocurrency transactions are all publicly viewable on a “blockchain,” the individual participants of each transaction cannot be easily determined. 
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