Federal Taxation

  • IRS Guidance on the Two Percent of AGI Floor for Trusts and Estates

    By:
    Kevin Matz, JD, LLM, CPA
    |
    Sep 1, 2014
    On May 9, 2014, the IRS issued final regulations under Treasury Regulations section 1.67-4 that provide guidance on which costs incurred by estates or trusts, other than grantor trusts (nongrantor trusts), are subject to the two percent of adjusted gross income (AGI) floor for miscellaneous itemized deductions under Internal Revenue Code (IRC) section 67(e).
  • The June 2014 Revised Offshore Voluntary Disclosure Program and Streamlined Programs

    By:
    Melissa Gillespie, JD, CPA, MST
    |
    Aug 1, 2014
    It has been interesting to watch the IRS mold and remodel its original 2009 Offshore Voluntary Disclosure Program (OVDP). Since then, updates have included the 2011 Offshore Voluntary Disclosure Initiative (OVDI), which closed in September 2011; the December 2011 new compliance procedures for nonresident U.S. taxpayers, with a promise of “more to follow”; the 2012 OVDP program, which replaced the 2011 OVDI; and the announcement in June 2012 of new streamlined filing compliance procedures for U.S. citizens or dual citizens residing outside the United States. On Jun. 18, 2014, it was announced that the IRS has once again revised its OVDP.
  • Fraud Risks and Prevention Techniques for Exempt Organizations

    By:
    David Zweighaft, CPA/CFE, CPE
    |
    Jun 10, 2014
    Reliance on documents is often the basis for initiating, recording, or approving accounting transactions—and, in a perfect world, that would be reasonable and acceptable. Unfortunately, there is always the risk of fraud in clients’ organizations.
  • Pressure Builds on U.S. Taxpayers with Foreign Accounts

    By:
    Robert Barnett, CPA, JD, MS (taxation) and Renato Matos, JD, LLM (taxation)
    |
    Jun 1, 2014
    The Foreign Account Tax Compliance Act of 2010 (FATCA) has manifested outside the United States in recent months, as a result of an agreement announced on Aug. 29, 2013, between the U.S. Department of Justice and the Swiss Federal Department of Finance.
  • Opting Out of the IRS Offshore Disclosure Programs

    By:
    Eric L. Morgenthal, Esq., CPA, MS (Taxation)
    |
    May 1, 2014
    In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In the years that followed, the program was reintroduced and revised. Soon enough, thousands of practitioners started jumping on the foreign tax repair bandwagon. Many had no foreign tax experience or held limited knowledge of the foreign tax reporting and compliance requirements.
  • Guaranteed 10-Pay Whole Life Insurance Contracts

    By:
    G. Dean Goodwin, CLUT, AEPT
    |
    May 1, 2014
    Most advisors and clients utilize the benefits of life insurance for the traditional purposes of replacing income or providing liquidity to pay estate taxes through the income tax-free death benefit; however, permanent insurance is often perceived as being expensive and not providing a competitive rate of return compared to other asset classes. In order to provide policyholders with a sense of certainty, a number of mutual insurance companies have introduced guaranteed 10-pay whole life contracts that are contractually paid-up with 10 years of premium payments, regardless of dividend performance.
  • Feared PFIC Regs Get New Twist - Tax Stringer March 2014

    By:
    Lisa S. Goldman, CPA, and Thomas V. Ruta, CPA
    |
    Mar 1, 2014
    Late last year, the IRS released Temporary Regulation 1.1298-1T under IRC Section 1298(f) dealing with the complicated and troublesome rules surrounding passive foreign investment companies (PFICs). These new regulations require certain U.S. taxpayers who own shares in PFICs to report information about their investments on an enhanced Form 8621. The rules also have a complex history, and CPAs practicing in the international arena should pay close attention to the fine print.
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