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Code Section 754: Allocating Gain Where it Belongs

Our Recommended Reading List on Tax Policy

Nothing to Fear but Fear Itself: Planning in the Current Environment
Final Subpart F Regulations and Domestic Partnership Tax Reporting
A Year in Review and an Outlook on the Horizon for Tax-Exempt Entities

Latest Articles

  • Helpful Instructions for Filing Domestic and Foreign Voluntary Disclosures

    By:
    Ellen S. Brody, JD, CPA, Esq., and David J. Snyder, JD
    |
    Jul 1, 2020

    In April 2020, the IRS quietly updated Form 14457. Previously called the “Offshore Voluntary Disclosure Letter,” the form’s name was changed to “Voluntary Disclosure Practice Preclearance Request and Application.” It had been used in conjunction with the Offshore Voluntary Disclosure Program (OVDP) that ended Sept. 28, 2018.

  • Can New York State Audit Federal Tax Issues?

    By:
    Brian Gordon, CPA
    |
    Jul 1, 2020

    In a typical case, the IRS will audit federal tax issues, and when audit changes are made, it will notify New York State. With little additional work, New York will bill the taxpayer the amount of additional state tax resulting from these federal tax changes. Taxpayers are required to report the IRS audit changes on a New York State amended return within 90 days of the IRS notification, regardless of whether they receive a bill from the state.

  • Protecting Yourself, Your Family, and Your Heirs during the COVID-19 Crisis

    By:
    Kevin Matz, Esq, CPA, LLM
    |
    Jun 1, 2020
    We live in unprecedented times. Many of the tenets we thought we knew at the beginning of March 2020 have now been shattered by COVID-19, which has wreaked havoc not only on our nation’s public health but also on the worldwide economy and the financial markets. 

  • Coronavirus and Nonprofits: Cancellation of Fundraising Events and Membership Dues May Convert to Tax-Deductible Donations

    By:
    Eva Mruk, Susan Barossi, CPA , and Garrett M. Higgins
    |
    Jun 1, 2020
    In the wake of the coronavirus (COVID-19) pandemic, charitable organizations around the world have been forced to cancel or postpone their fundraising events. In addition, many charitable organizations have been advised to close their facilities and perform their operations virtually, if possible. As a result, nonprofits that collect membership dues, tuition, or fees can render limited or even no services in exchange.

  • New PTIN User Fee: IRS Announcement Despite Ongoing Remand Litigation

    By:
    Frank G. Colella, Esq, LLM, CPA
    |
    Jun 1, 2020
    The IRS recently announced its intention to reimpose a practitioner tax identification number (PTIN) user fee for the 2020 tax season. The proposed regulation requires tax practitioners to pay $21 (plus a vendor fee) to obtain or renew their PTINs.

  • Equity and Equity-Based Compensation for LLCs

    By:
    Robert M. Finkel
    |
    Jun 1, 2020
    The structures for granting equity incentives to employees and other service providers of corporations are tried and true. The income tax consequences to a grantee upon his receipt of restricted stock and stock options and to the issuing corporations are well settled.

  • COVID-19 Emergency Tax Postponement Relief: The IRS Expands Its Scope

    By:
    Kevin Matz, JD, Esq., CPA, LLM
    |
    May 1, 2020
    On Apr. 9, 2020, as a further response to COVID-19, the U.S. Treasury Department and the IRS issued Notice 2020-23, which significantly expanded the scope of the emergency tax postponement relief. The relief granted by the new notice covers taxpayers who have an IRS tax filing or payment deadline between Apr. 1 and Jul. 15, 2020.

  • Estate Planning for Founders and Investors in Venture-backed Companies: Transfers of Qualified Small Business Stock by Gift

    By:
    Michael S. Arlein and Brian M. Sweet
    |
    May 1, 2020
    Congress first enacted IRC section 1202 in 1993 to encourage investment in specific types of small businesses by providing an exclusion of certain gain from the sale or exchange of qualified small business stock (QSBS). The original benefits of IRC section 1202 attracted moderate attention, but those benefits were significantly enhanced in subsequent decades, most notably under the Small Business and Jobs Act of 2010.

  • Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?

    By:
    Ellen S. Brody, JD, Esq., CPA and Menahem M. Grossman, Esq.
    |
    May 1, 2020
    The IRC imposes various penalties on taxpayers who fail to comply with the obligations it sets forth for them. However, taxpayers can often avoid penalties if they can prove that their failure was due to reasonable cause and that they acted in good faith [IRC section 6664(c)(1)].

  • Tax Exemption: What Nonprofit Executives, Board Members, and Auditors Need to Know (Part 2 of 2)

    By:
    Allen L. Fetterman, CPA, MBA
    |
    May 1, 2020
    Published in the April issue of TaxStringer, part 1 of this series provided a beginning overview of the basics of tax exemption. This article will continue that discussion, focusing especially on tax exemption with respect to jeopardizing tax-exempt status, lobbying, the Form 990 series, and state laws.
Page

Tax Cases


In Case You Missed It – May 2023
Tax Jokes
  

Which Avenger pays the least taxes? Spider-Man, because his income is all net.

https://parade.com/1317763/jessicasager/accounting-jokes/

Tax News


IRS, Other Agencies Issue COVID-19 FAQs in Response to Impending End of Public Health Emergency,The Trusted Professional

Tax Court Rules IRS Does Not Have Statutory Authority to Assess Penalties for Failure to File Form 5471,Forbes Media LLC

IRS Revises Guidance on Bitcoin, in Light of Its Use As Legal Tender in Some Nations,The Trusted Professional

Hight Court Considering Case on Whether IRS Can Secretly Obtain Bank Records of Taxpayer's Relatives,The Trusted Professional

More Foreign Companies Than Expected May Be Subject to 1% Buyback Tax,The Trusted Professional

After Beyoncé Failed to Work It Out With IRS, She Filed A Petition in Tax Court,Forbes Media LLC

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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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.