Revenue Procedure 2016-49 answers in the affirmative the question of whether the IRS will respect a qualified terminable interest property (“QTIP”) election where the executor has elected portability of the deceased spousal unused exclusion (“DSUE”) amount under IRC section 2010(c)(5)(A).  

Many tax clients think that the tax withholding rules apply only to those in business. They are familiar with withholding on employee wages and may have even needed to withhold tax on income allocated or paid to a foreign investor in their company; however, most clients do not expect a federal tax withholding requirement when making payments for personal purposes—which is why the rules surrounding the purchase of a home may come as a surprise.

Financial and legal advisors representing entertainers and professional athletes—“celebrities”—confront unique circumstances not usually present when working with more traditional clients. These challenges include the “sudden wealth” effect, short earnings horizon, inconsistent cash flow, unrestrained spending habits, limited financial literacy, and incompetent advising.

After more than 35 years of “buyer beware” warnings, why do consumers continue to purchase flexible premium non-guaranteed death benefit life insurance products for a 10 to 50 year planning duration period, assume policy performance risk without knowing the risks to be managed, and forego annual policy performance monitoring—all while knowing there is a high probability that the policy will lapse without value during their lifetimes? 

The IRS's Taxpayer Advocate Service (TAS) can help you help your clients. If your client is having a tax problem that you haven’t been able to resolve on your own, our advocates may be able to help. Your client may be eligible for our help if his or her IRS problem is causing financial difficulty, or if you believe an IRS procedure just isn't working as it should.

Hedge fund K-1s can be voluminous and difficult when determining how to handle the tax treatment of the income and deductions at the individual level. This article will help you navigate K-1s to understand how certain items would impact the tax treatment at the individual level. The first step in determining the proper treatment of income and expense items is to identify whether the partnership is a trader fund, investor fund, or fund of funds.

Straddles are defined in IRC section 1092(c) as two or more offsetting positions in personal property. A taxpayer holds offsetting positions with respect to personal property if the taxpayer’s risk of loss from holding any position is substantially reduced by reason of their holding one or more other positions with respect to personal property—whether or not of the same kind. 

Fall is an amazing time of the year for sports fans. The NFL season is in full swing, the NBA and NHL seasons are beginning, and—of course—baseball’s World Series is played. As both sports enthusiasts and state and local tax professionals, we also focus on how professional athletes must report their taxes to various states.