Limited partner’s investment interest from trader partnership deductible above-the-line Rev Rul 2008-38, 2008-31 IRB; Ann. 2008-65, 2008-31 IRB Mike Habib, EA Earlier this year, IRS issued Rev Rul 2008-12, 2008-10 IRB 520 concluding that where a non-corporate limited partner doesn’t materially participate in the partnership’s activity, his distributive share of…
Judge: IRS can seek tax information from Swiss banking giant UBS in expanding investigation Associated Press WorldStream via NewsEdge : MIAMI_A federal judge agreed Tuesday to allow the IRS to serve legal papers on Swiss banking giant UBS AG in an expanding investigation into U.S. taxpayers who may have used…
Final regs on dependent child of divorced or separated parents or parents who live apart T.D. 9408, 07/01/2008; Reg. § 1.152-4 Mike Habib, EA IRS has issued final regs on the rules for claiming a child as a dependent by parents who are divorced, legally separated under a decree of…
TIGTA results of 2008 review IRS compliance with legal guidelines when conducting property seizures [Audit Report No. 2008-30-126]: IRS has usually followed the numerous legal and internal guidelines that apply to seizures of taxpayers’ property, the Treasury Inspector General for Tax Administration (TIGTA) said in a recent audit. TIGTA based…
Loan repayment to shareholder’s spouse wasn’t constructive distribution Beckley, 130 TC No. 18 (2008) Mike Habib, EA The Tax Court has ruled that payments made by a corporation to the wife of one of its shareholders represented repayment of money she advanced to a predecessor corporation. Despite the absence of…
Final regs include new process for reporting employment tax adjustments and refund claims T.D. 9405, 06/30/2008, Reg. § 31.6011(a)-1, Reg. § 31.6011(a)-4, Reg. § 31.6011(a)-5, Reg. § 31.6205-1, Reg. § 31.6302-1, Reg. § 31.6402(a)-1, Reg. § 31.6413(a)-1, Reg. § 31.6403(a)-2 Mike Habib, EA IRS has issued final regs on employment…
Gain from selling carbon dioxide allowances didn’t generate foreign personal holding company income PLR 200825009 Mike Habib, EA IRS has privately ruled that gain from the sale of surplus carbon dioxide allowances didn’t constitute foreign personal holding company income (FPHCI) under Code Sec. 954(c). It concluded that the emissions allowances…
House Subcommittee Passes IRS Funding Bill The House Appropriations Financial Services Subcommittee this week passed a bill that would appropriate $11.4 billion to IRS for FY 2009. The bill would grant IRS budget authority to spend $5.1 billion on enforcement, $2.2 on taxpayer services, and $3.8 billion on operations. The…
More disaster victims in Indiana, Iowa and Wisconsin qualify for tax relief IRS website [https://www.irs.gov/newsroom/article/0,,id=108362,00.html] Mike Habib, EA IRS has announced on its website that additional counties in Indiana, Iowa and Wisconsin have been declared disaster areas on account of recent severe storms, tornadoes and flooding. As a result, more…
Regs crack down on tax avoidance repatriations of CFC earnings Preamble to TD 9402, 06/23/2008; Reg. § 1.956-1T; Preamble to Prop Reg 06/23/2008; Prop Reg § 1.956-1 Mike Habib, EA IRS has issued temporary and proposed regs to determine the basis of certain U.S. property acquired by a controlled foreign…