A major convenience in smartphone technology is the availability of third-party payment networks like Venmo and PayPal, which replace payments by cash, check, or debit card. The IRS calls these transactions, third-party network transactions (TPNTs)...
Taxation Articles
WHAT ARE THE CHANCES OF BEING AUDITED BY THE IRS?
My son’s scariest Halloween costume was a T-shirt bearing the words “IRS Audit Agent.” An audit can be a terrifying experience. The prospect of defending everything that you have sworn was true on your income tax return and justifying everything...
SUBJECTIVE DETERMINATION AND OBJECTIVE
DETERMINATION FOR CLAIMING A WORTHLESS
SECURITY LOSS DEDUCTION
Tax counsel often advise taxpayers to apply Internal Revenue Code (Code) section 165(a) to claim an income tax deduction for an uncompensated loss sustained during the tax year. An uncompensated loss occurs when the taxpayer receives insurance...
IRREVOCABLE INSURANCE TRUST PLANNING AND ADMINISTRATION FOR THE NEW TAX AGE
Insurance. The word itself evokes different reactions. The range of emotions expands when we mention life insurance. And if we add the word trust–life insurance trust–clients may stop listening altogether. But now is exactly the time to be thinking...
TAXATION CONSIDERATIONS RELATED TO EQUITY INCENTIVE COMPENSATION PLANS
With labor shortages currently affecting many industries and with the low national unemployment rate, many private company owners are considering compensation incentives to attract and retain high quality employees. For years, tax counsel have...
KIDS, CRYPTO, AND TAXES: AVOIDING THE HEADACHES
Virtual currency is, by most objective standards, a new asset class. The oldest virtual currency is Bitcoin, which launched in 2009. In recent years, there has been a proliferation of technologies developed on Bitcoin’s promise of distributed...
QUESTIONS AND ANSWERS ABOUT OFFSET BYPASS REFUNDS
If a taxpayer has delinquent tax debts, the taxpayer will generally not receive any tax return refunds due to him.1 The IRS will typically apply whatever refund that taxpayer is owed to a prior year’s tax debt. For example, if a taxpayer has a...
Estate Planners Gain Precedent on Passthrough Valuation Maneuver
Estate planners should heap praise on a recent Tax Court holding that cracked open a door on a technique long viewed as sealed shut on allowing taxpayers to discount earnings from a passthrough entity. Estate Planners Gain Precedent on Passthrough...
Co-Directors of SEC Division of Enforcement to Speak at Upcoming Conference
ALI CLE | Accountants' Liability 2019: Strategies for the Profession in an Era of Heightened Enforcement | October 17 - 18 2019 | Washington, D.C. Washington, D.C., August 21, 2019. American Law Institute Continuing Legal Education (ALI CLE) has...