Courts do not agree on IRS regulation

Several courts are addressing the legality of an IRS regulation, with mixed results.   Late last year, the IRS issued final regulations describing conditions under which it will be allowed six years – instead of the normal three years – to assess additional tax...

What’s new from Congress

Congress has passed, and the President has signed, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011. This bill repeals the expansion of the Form 1099 reporting requirement contained in 2010 legislation. Former...

What’s new from the IRS

A new revenue procedure creates a safe harbor for companies that have incurred “success fees.” Success-based fees are amounts that are contingent on the successful closing of a transaction (most often, investment banker fees). They are presumed to...

What’s new from the courts

In a case dealing with a charitable contribution for a façade easement, the Tax Court ruled that the gift did not result in a charitable contribution deduction because a bank held a mortgage on the underlying property. The easement involved a single-family rowhouse...

It bears repeating

Because of its catastrophic nature, the earthquake and tsunami that hit Japan last month is a qualified disaster for purposes of the federal tax law, according to the IRS. Similar determinations have been made regarding prior international disasters,...