by apexcpas | Jul 4, 2018 | Tax Planning
The IRS has issued a memorandum describing the penalty framework that will apply to those who voluntarily disclose assets hidden in offshore accounts. The new program is a followup to voluntary disclosure efforts conducted two years ago. Every U.S. citizen who has a...
by apexcpas | Jul 4, 2018 | Tax Planning
The Supreme Court has refused, without comment, to bypass the court of appeals and review a Virginia district court decision that challenges the constitutionality of the Patient Protection and Affordable Care Act. In Virginia ex rel. Cuccinelli v. Sebelius...
by apexcpas | Jul 4, 2018 | Tax Planning
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...
by apexcpas | Jul 4, 2018 | Tax Planning
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...
by apexcpas | Jul 4, 2018 | Tax Planning
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...
by apexcpas | Jul 4, 2018 | Tax Planning
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...