Guidance on timing of PPA-related amendments for calculating plan cash-outs starting in 2008
Mike Habib, EA
myIRSTaxRelief.com
IRS has issued guidance, in question and answer format, that addresses the timing of plan amendments made to comply with Sec. 302 of the Pension Protection Act of 2006 (PPA 2006, P.L. 109-280, Sec. 302), which changed the statutory assumptions that must be used beginning in 2008 for calculating the present value of plan cash-outs.
IRS explains how to correct a failure to follow retirement plan terms
Retirement News for Employers
In its Retirement News for Employers, IRS has explained how to correct the common retirement plan mistake of failing to follow the plan terms in its operation. IRS clarified when a plan amendment can be used to correct this mistake via the Employee Plans Compliance Resolution System’s (EPCRS) Self-Correction Program (SCP).
IRS provides guidance on new rules for employment tax levies
The IRS has issued interim guidance to its directors and collection area offices that explains when it is permissible to issue a levy to collect employment taxes without first giving the taxpayer a pre-levy collection due process (CDP) notice.
Distressed asset trust transactions identified as listed transactions
In a Notice, the IRS has identified a distressed asset trust (DAT) transaction as a listed transaction under Reg. § 1.6011-4(b)(2), Code Sec. 6111 and Code Sec. 6112. In such a transaction, a tax-indifferent party contributes one or more distressed assets with a high basis and low fair market value to a trust or series of trusts and sub-trusts, and a U.S. taxpayer acquires an interest in the trust for the purpose of shifting a built-in loss from the tax-indifferent party to the U.S. taxpayer that has not incurred the economic loss.
Reconstructing records after a disaster may be essential for tax purposes, getting federal assistance or insurance reimbursement. Records that you need to prove your loss may have been damaged or destroyed in a casualty. While it may not be easy, reconstructing your records may be essential for:
As per the IRS Offer in Compromise
If taxpayers are unable to pay a tax debt in full and an installment agreement is not an option, they may be able to take advantage of an offer in compromise (OIC). Generally, an OIC should be viewed as a last resort after taxpayers have explored all other available payment options. The IRS resolves less than one percent of all balance due accounts through the OIC program.
Most common questions by corporations and other business entities on 1099 reporting requirements. Below is a direct IRS response to frequently asked question on 1099 issues.
IRS provides further guidance on Form 1099 reporting
IRS and treaty partners target Liechtenstein accounts
An IRS news release reports that IRS is initiating enforcement action involving more than 100 U.S. taxpayers to ensure proper income reporting and tax payment in connection with accounts in Liechtenstein.
Supreme Court won’t review case holding that partner must pay tax on escrowed disputed funds
The Supreme Court has declined to review a decision of the U.S. Court of Appeals for the First Circuit that an individual who was a partner in a partnership had to pay tax on his distributive share of the partnership’s income, notwithstanding that the partnership’s receipts had been placed in escrow pending the outcome of a suit by the individual against the other partner.
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