Publications Archives - Page 21 of 26

Planning and Tax Considerations for Collectibles: Assisting Hobbyists, Dealers, and Investors

By Sidney Kess and Edward Mendlowitz CPA Journal November 2017 Issue Many individuals have substantial investments in collectibles, such as art, stamps, coins, autographs, books, maps, baseball cards, glassware, antiques, gems, jewelry, or wine. The category is broad and does not distinguish between the motive

Acquisitions, Dispositions & Structuring Techniques Corner: Tax Court’s Recent Decision In Mckelvey Est., Affirms Merits Of Deferring Gain Under A Variable Prepaid Forward Contract

By Jerald David August Journal of Passthrough Entities September – October 2017 Edition In McKelvey, the executor of the taxpayer’s estate petitioned for a redetermination of the $41.26M deficiency in income tax for 2008, processed by the IRS, attributable to his entering into various variable prepaid forward

Using Bitcoin To Buy A Sandwich Could Trigger A Tax Bill

Op-Ed By Bryan C. Skarlatos Featured on CNBC Crypto currencies may have been around for less than a decade, but they are proliferating so quickly that our established tax and regulatory systems can’t keep up. And that could create serious tax problems for those who would

Executor And Beneficiary Liability For Unpaid Income, Gift, And Estate Taxes Of A Decedent

By Jerald David August The CPA Journal October 2017 Edition Tax advisors of estates are generally aware that the executor or personal representative of the estate is personally liable for the payment of federal estate taxes not only with respect to the probate estate, but also

Digital Currency: Taxation, Enforcement, And The John Doe Summons

By Michael Sardar The CPA Journal September 2017 Edition Several years ago, the IRS started its successful takedown of secret Swiss banking with the use of a John Doe summons. Full Article

A Crash Course On Reportable Transaction Penalties For Material Advisors

By Megan L. Brackney Journal of Taxation October 2017 Edition After a long period of inactivity, the IRS has recently released four notices identifying new reportable transactions. Full Article

The Variance Doctrine: An Important Variable To Consider When Drafting Refund Claims

By Megan L. Brackney Journal of Passthrough Entities September – October 2017 Edition If you are preparing, or advising on, the filing of amended returns or other claims for refund, one of the most important things to consider is the variance doctrine, and how it could

Partnership Audit Rules – Drafting Partnership Agreements: The New Partnership Representative And The Outgoing Tax Matters Partner

By Jerald David August Corporate Taxation September 2017 Edition Although new partnership audit rules have been enacted, the TEFRA entity-level audit rules, particularly the tax manger partner rules, continue to be relevant. Full Article

The Many Faces Of Form 3520

By Ian Weinstock The CPA Journal August 2017 Edition Form 3520 is an information return for a U.S. person to report certain transactions with foreign trusts [as defined in Internal Revenue Code (IRC) section 7701(a)(31)] or to report the receipt of certain foreign gifts or bequests.

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the

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