The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their
Read more →IRS Chief Counsel (CCA 201436049) has concluded that so-called limited partners of an investment management firm were not limited partners of the firm (a limited liability company (LLC) treated as a partnership) and were being paid compensation for services. Therefore, the amounts they received from the firm
Read more →The Internal Revenue Service is diligently working to stop fraud perpetrated by persons who buy or steal Social Security numbers. Tax identity theft is a growing problem that affects millions of Americans, but “it’s gone from hundreds of people filing hundreds of fraudulent returns to thousands of
Read more →The Treasury and the IRS have announced that they will be taking targeted action against corporations employing a technique known as a tax inversion in order to avoid taxation, and have issued a fact sheet and a Notice in that respect. What happens with an inversion, is
Read more →The Individual Shared Responsibility Payment Beginning in 2014, the individual shared responsibility provision of the Affordable Care Act requires each individual to: Maintain a minimum level of health care coverage – known as minimum essential coverage , or Qualify for an exemption , or Make an individual
Read more →On June 18, 2014, the IRS announced comprehensive changes to both the Streamlined and the Offshore Voluntary Disclosure Program (“OVDP”) programs. Such changes to the Streamline Program include: Streamlined Program 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States 2.
Read more →Commissioner John Koskinen recently cautioned taxpayers they should expect more reductions in IRS services because of budget cuts. Koskinen’s warning comes as the IRS prepares for year-end tax legislation as well as implementing its voluntary return preparer education program and combatting tax-related identity theft. According to Fred
Read more →Section 45R(a) provides for a health insurance tax credit for eligible small employers for any taxable year in which they have a qualified contribution arrangement, have no more than 25 full-time equivalent employees (FTEs), and the average annual wages of its FTEs does not exceed $25,000 (as
Read more →This week the Internal Revenue Service announced the adoption of a “Taxpayer Bill of Rights” that will become the primary document to provide U.S. taxpayers with a better understanding of their rights. The Taxpayer Bill of Rights takes the multiple existing rights embedded in the tax code
Read more →As an Entrepreneur one of our primary concerns is to keep costs down and increase revenue. But to increase revenue does NOT mean we have to put all of our money into marketing our firm and hiring the best PR firm out there. Mark Cuban sums it
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