Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Thelma G. Hurford, TC Memo 2008-278 (Dec. 11, 2008).The Tax Court rejected an overly aggressive plan for a surviving wife who had been diagnosed with stage...
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According to CCH, the IRS has issued procedures for eligible small employers to elect out of filing Form 944, Employers Annual Federal Tax Return, but instead to continue to file Form 941, Employer's QUARTERLY Federal Tax Return. Guidance is also...
Continue reading "Rev. Proc. 2009-13 - Procedure for Electing Out of Form 944"
REG-113462-08 contains proposed regulations relating to conduit financing arrangements issued under the authority granted by IRC Sec. 7701(l). The proposed regs apply to multiple-party financing arrangements that are effected through disregarded entities, and are necessary in order to determine which...
The IRS has issued TD 9440, which contains temporary regulations relating to the annual filing of Federal employment tax returns and requirements for employment tax deposits. These temporary regulations relate to IRC Secs. 6011 and 6302 concerning reporting and paying...
The competent authorities of the United States and Germany recently signed an arrangement to provide guidance for operating the arbitration procedure that went into force on Dec. 28, 2008. For details on this arrangement, go to IRS.gov. Posted by Lewis...
REG-160872-04 contains proposed regulations under IRC Section 6707, which provide the rules relating to the assessment of penalties against material advisors who fail to timely file a true and complete return required under IRC Section 6111(a) for reportable transactions. The...
IRS Notice 2009-01 modifies Notice 2001-55, 2001-2 CB 299, and provides that a section 529 program (qualified tuition program) does not violate the investment restriction under IRC Sec. 529(b)(4) if it permits a participant to change investment strategy selected for...
The IRS, in Notice 2008-114, has published tables showing the amount of an individual's income that is exempt from a notice of levy used to collect delinquent tax in 2009. This information is the same as that found in Publication...
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Mark Merric, of the Merric Law Firm, LLC, in Denver, CO, has announced that the following articles, authored by Mr. Merric, were published in Stephan Leimberg's LISI service during this last quarter. Spousal Lifetime Access Trusts - Part II; ...
The IRS's next Tax Talk Today program, "Getting Ready for Filing Season 2009 -- Individual and Business," will be Tuesday, Jan. 13, at 2 p.m. This special, 100-minute program will give tax preparers a head start on the 2009 filing...
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Revenue Ruling 2009-02 provides the covered compensation tables under section 401 of the Code for the year 2009 for use in determining contributions to defined benefit plans and permitted disparity. Revenue Ruling 2009-02 will appear in IRB 2009-2, dated...
Revenue Ruling 2009-01, provides various prescribed rates for federal income tax purposes including the applicable federal interest rates, the adjusted applicable federal interest rates, the adjusted federal long-term rate, the adjusted federal long-term tax-exempt rate. These rates are determined as...
By now, virtually everyone knows that Bernard Lawrence Madoff (born April 29, 1938) is an American businessman and former Chairman of the NASDAQ stock market, who was the former founder of the Wall Street firm Bernard L. Madoff Investment Securities...
Continue reading "Proskauer Rose Seminar on Bernard Madoff Case"
The IRS has issued the following updated guidance on tax return preparer penalties:Notice 2009-05. Provides guidance regarding implementation of the tax return prepare penalty under section 6694(a). The Service is also requesting comments on the interim guidelines in this notice. ...
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The IRS has announced an expedited process that will make it easier for financially distressed homeowners to avoid having a federal tax lien block refinancing of mortgages or the sale of a home. It stated today that i taxpayers are...
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New tax treaties (and accompanying protocols) with Bulgaria and Iceland and a protocol amending the existing tax treaty with Canada entered into force December 15, 2008. All are generally effective for tax years beginning on or after January 1, 2009....
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H.R. 7327 was passed by the House on December 11, 2008 by unanimous consent. H.R. 7327 is virtually identical to the pension package the Senate hotlined on Thursday, November 20th, except H.R. 7327 does not include three provisions - provisions...
Continue reading "Senate Passes HR 7327 - The Worker, Retiree, and Employer Recovery Act of 2008"
Notice 2009-03 provides relief for sponsors of 403(b) retirement plans with respect to the requirement to have a written § 403(b) plan in place by January 1, 2009. This notice also briefly describes other programs the Service intends to establish...
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The U.S. House of Representatives approved legislation today that would temporarily suspend an excise tax which is assessed on seniors who fail to take a required minimum distribution (RMD) from their retirement accounts including IRAs, 401(k)s, and 403(b)s. The bill...
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In Notice 2008-115, the IRS extends the transition rules for employers and payers re reporting and wage withholding requirements for deferrals of compensation and amounts includible in gross income under IRC Section 409A, and the transition rules for computing includible...
Notice 2008-116 provides interim guidance with regard to the application of the 2-percent floor under section 67 to certain investment advisory fees. Specifically, this notice provides that, for taxable years beginning before January 1, 2009, non-grantor trusts and estates will...
Ernst & Young invites you to watch their Thought Center Webcast, which will give you an opportunity to hear analysis and commentary on the potential implications of the elections, as well as the possibility of legislative activity during a lame-duck...
Continue reading "E&Y Webcast - "Post-presidential election tax update: what's next?"
FinCEN has released its new Bank Secrecy Act/Anti-Money Laundering Manual for Money Services Businesses, which provides guidance to officials examining money services businesses (MSBs) for compliance with the requirements of the Bank Secrecy Act (BSA). Posted by Lewis J. Saret, General...
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The IRS, in IR-2008-138, offered tips for individuals and businesses making contributions to charity re relatively new tax law provisions. These are as follows. Special Charitable Contributions for Certain IRA Owners An IRA owner, age 70 ½ or over, can...
The Treasury Department has announced that the US and Liechtenstein have signed a Tax Information Exchange Agreement (TIEA) allowing for exchange of information on tax matters between the two countries. The agreement was signed by U.S. Charge d'Affairs Leigh Carter...
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Notice 2008-113 gives taxpayers the ability to correct certain operational failures to comply with section 409A of the Internal Revenue Code,, or to limit the amount of additional taxes due to the failure to comply with section 409A. Section 409A...
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The following article has been posted on the Wealth Strategies Journal 2.0:2008 Year-End Tax Planning, by Bradley M. Van Buren....
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The IRS issued Notice 2008-111, which clarifies Notice 2001-16, 2001-1 C.B. 730, and supersedes Notice 2008-20, 2008-6 I.R.B. 406, regarding Intermediary Transaction Tax Shelters ("Intermediary Transaction"). Notice 2001-16 identified the Intermediary Transaction as a listed transaction under § 1.6011-4(b)(2) of the...
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IRS Rev. Rul. 2008-52 provides 2009 inflation adjusted dollar amounts for IRC Section 1274. Rev. Rul. 2008-52 will be published in IRB 2008-49, dated December 8, 2008.Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal. ...
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IRS Notice 2008-109 provides information on the midwestern and hurricane Ike disaster areas and population estimates. It will be published in IRB 2008-50, dated December 15, 2008.Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal. ...
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IRS Notice 2008-108 contains the 2008 cumulative list of changes in plan qualification requirements. It will be published in IRB 2008-50, dated December 15, 2008.Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal. ...
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Taxpayers who make qualifying cash contributions for disaster relief efforts in the Midwest could benefit from a recently passed law that suspends the percentage-of-income limits that would normally apply when taxpayers deduct the contributions on their 2008 federal tax returns.Under...
The fall 2008 Statistics of Income Bulletin is now available online. Among other things, it features information on 138.4 million individual income tax returns filed for tax year 2006.Adjusted gross income less deficit (losses) reported for 2006 totaled $8.0 trillion,...
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The IRS issued the 2009 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes.Beginning on Jan. 1, 2009, the standard mileage rates for the use of a car...
