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Federal Taxation

  • Federal and Tri-State Area Income Tax Treatment of Amortizable Bond Premium

    By:
    David M. Barral, CPA/PFS, CFP®, MS (taxation)
    |
    Sep 1, 2021

    A bond investor generally recognizes two characters of income during the bond’s term: interest income from the coupon payments, and a capital gain/loss when the bond matures (or is disposed of). During the bond’s term, they may have to address any Amortizable Bond Premium (ABP) for income tax purposes. ABP is equal to the excess of the purchase price over the face/par value, and is typically incurred when the interest rate on the bond is paying more than the prevailing interest rates on bonds.

  • Recent Administrative and Judicial Developments in IRS Appeals

    By:
    Frank G. Colella, Esq., LLM, CPA
    |
    Sep 1, 2021
    Since enactment of the Taxpayer First Act (TFA) in July 2019, the IRS has issued subregulatory guidance to implement the major new provisions affecting appeals, including a memorandum on taxpayer access to the appeals office and a memorandum on taxpayer access to case files prior to scheduled appeals conferences.  In addition, recent court decisions have also dealt with appeals-related issues, including challenges over the scope of the right to appeal under the TFA.

  • Cash Method? Avoid The Tax Shelter Trap

    By:
    Robert S. Barnett, JD, MS (Taxation), CPA
    |
    Aug 1, 2021
    Many taxpayers will need to consider the recent small business taxpayer regulations. On January 5, 2021, the IRS released final regulations[1] that provide guidance on the implementation of several provisions of the Tax Cuts and Jobs Act (TCJA).[2] The final regulations address several important tax provisions including the following: limitation on use of the cash method of accounting, exemption from inventory methods required under IRC § 471, uniform capitalization requirements under § 263A, and the percentage of completion method for certain long-term construction contracts under § 460A.

  • The Deemed Realization Proposal in the Biden Administration’s “Green Book”

    By:
    Kevin Matz, Esq., CPA, LL.M. (Taxation)
    |
    Jul 1, 2021
    On May 28, 2021, the U.S. Treasury Department released its General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (which is popularly called the “Green Book”). Significantly, the Green Book does not propose any changes to federal estate and gift taxes—in stark contrast to the previous Green Book that the Obama administration had released back in 2016, which had proposed vast changes to the estate and gift tax system.

  • Buy-Sell Agreements: The Accountant’s Holistic Primer Part 2

    By:
    Joshua P. Friedlander, Matthew E. Rappaport, Esq., LLM and Daniel J. Gershman, JD
    |
    Jun 1, 2021

    For companies where ownership is vested exclusively in one individual, there is often a need to address continuity of the company in the event of the sole owner’s death or incapacity. The surviving spouse of an owner may not want to be encumbered with a business foreign to him, and an unclear line of succession could lead to in-fighting or panicking among employees at all levels of the business; in this way, an asset that has produced income for loved ones in the past now becomes a potential liability. 

  • Buy-Sell Agreements: The Accountant’s Holistic Primer, Part 1

    By:
    Joshua P. Friedlander, Matthew E. Rappaport, Esq., LLM, and Daniel J. Gershman, JD
    |
    May 1, 2021
    This is the first of a two-part article on buy-sell agreements. The second part will be featured in the June TaxStringer.

    Most accountants are familiar with the concept of Buy-Sell Agreements, and after practicing long enough, most accountants are involved in planning several Buy-Sell Agreements and administering at least a few of them. Buy-Sell Agreements create the mechanism for an entity and its owners to experience an orderly transition of equity ownership and governance upon a wide range of events that might include death, disability, retirement, voluntary withdrawal, or an impasse among the owners.

  • How to Determine the Section 199A Deduction for Your Client

    By:
    Cameron Williams, CPA
    |
    May 1, 2021

    The qualified business income (QBI) deduction under Internal Revenue Code (IRC) Section 199A introduces challenges and benefits for owners of pass-through businesses. Although the deduction can provide a significant tax opportunity, navigating the many rules and limitations associated with it can be complicated and time consuming. Here, learn key applications and requirements when determining the QBI deduction for taxpayers who receive QBI from multiple sources, such as Schedule K-1s and rental properties.
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Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.