U.S. Government Reportedly Reviewing Concerns with Patient Protection & Affordable Care Act Calculator

The federal calculator used to determine whether an employer-sponsored insurance plan provides minimum value under the Patient Protection and Affordable Care Act (PPACA) (P.L. 111-148) appears to be malfunctioning, according to benefits experts who are eagerly awaiting guidance from the Treasury Department on a possible fix. The

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IRS Will Work with Taxpayers Liable for Individual Shared Responsibility Payment

Individuals liable for the Code Sec. 5000A shared responsibility payment will make their payments when they file their 2014 returns, William Smits, senior manager, IRS Wage & Investment Division, National ACA Outreach Coordinator for Individual Tax Provisions, reminded practitioners during a webcast sponsored by the American Institute

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IRS Provides IRA Owners with Fresh Start for Rollovers in 2015

The IRS has provided transition relief for its change in the one-per-year limit imposed on tax-free rollovers between Individual Retirement Account (IRA) announced in March 2014. and scheduled to go into effect January 1, 2015. Under the change, the one-per-year rule applies to each individual rather than

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Regulations to be Proposed Will Require Employer-Sponsored Group Health Plans to Include In-Patient Hospitalization Services

The IRS has announced that the Department of Health and Human Services (HHS) and the Treasury Department (including the IRS) will soon issue proposed regulations providing that a group health plan does not provide minimum value if it excludes substantial coverage to employees for in-patient hospitalization services

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Action Needed to Ensure Tax Compliace with FIRPTA

According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.

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US Treasury Official Discusses BEPS and Other International Tax Developments

Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found

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Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

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

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Chief Counsel on What Makes Amounts Paid To “Limited Partners” of an LLC Subject To Self-Employment Taxes

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

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