New IRS settlement initiative for LILO and SILO transactions Mike Habib, EA IRS recently announced a settlement initiative for Lease-In/Lease-Out (LILO) and Sale-in/Lease-Out (SILO) transactions. Under this initiative, more than 45 of the nation’s largest corporations that participated in these shelters will receive a letter with an offer. Shelter participants…
Proposed regs explain strict charitable contribution substantiation & appraisal rules Preamble to Prop Reg 08/06/2008; Prop Reg § 1.170A-15, Prop Reg § 1.170A-16, Prop Reg § 1.170A-17, Prop Reg § 1.170A-18 Mike Habib, EA IRS has issued proposed regs explaining the charitable contribution substantiation changes made by the American Jobs…
Finance Chairman Baucus wants more action and details on IRS strategy to combat identity fraud [Press release dated Aug. 5]: A recent IRS update on its Identity Protection Strategy has failed to satisfy the concerns of Sen. Max Baucus (D-MT), chairman of the Senate Finance Committee. The report, submitted to…
IRS issues new version of Central Withholding Agreement form Mike Habib, EA The IRS has issued a June 2008 version of Form 13930, Application for Central Withholding Agreement. Under IRC §1441(a), nonresident alien (NRA) individuals are subject to 30% withholding on the gross amount of interest, dividends, rent, salaries, wages,…
IRS may require reporting of PAL activity groupings Mike Habib, EA Notice 2008-64, 2008-31 IRB 268 A new notice requests comments regarding a proposal to require taxpayers to report to IRS their groupings and regroupings of activities and the addition and disposition of specific activities within their existing groupings of…
Innocent spouse relieved of tax from embezzlement and forgery Yakubik, TC Summary Opinion 2008-74 Mike Habib, EA The Tax Court recently held that the IRS abused its discretion in not granting equitable innocent spouse relief to a husband whose wife embezzled funds from her employer and forged checks taken from…
IRS explains how to claim (or elect out of) 50% Kansas bonus depreciation Notice 2008-67, 2008-32 IRB Mike Habib, EA The Food, Conservation and Energy Act of 2008, popularly known as the Farm Act, provided temporary GO Zone-style tax relief for taxpayers in Kiowa County, Kansas, and surrounding areas, who…
Doctors get socked with big tax and penalties for donations tied to consolidation of their practice Berquistist and Kendrick, et al., (2008) 131 TC No. 2 Mike Habib, EA The Tax Court has determined that doctors grossly overvalued charitable donations of stock in their medical professional service corporation (PSC) that…
Proposed revenue ruling gives green light to use of private trust companies Notice 2008-63, 2008-31 IRB Mike Habib, EA A new notice contains a proposed revenue ruling that would allow families to use private trust companies (PTCs) in their estate planning without adverse income, estate, gift or generation-skipping transfer (GST)…
Charitable remainder trust can be divided into separate trusts without adverse tax consequences Rev Rul 2008-41, 2008-30 IRB Mike Habib, EA In the context of two fairly detailed factual situations, a new revenue ruling makes it clear that a charitable remainder trust (CRT) can be divided into two or more…