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Section 199A - Navigating the Maze of the New Pass-Through Deduction
By on January 25, 2018
For taxable years beginning after December 31, 2017 and before January 1, 2026 individuals and trusts are entitled to deduct 20% of their share of qualified business income from partnerships, S corporations and sole proprietorships (loosely referred to for these purposes as "pass-throughs"). . . Ahhh, if only § 199A were so simple. However this seemingly simple deduction is in fact layered with enough limitations, exemptions and phase-ins to make one's head spin.
By on January 24, 2018
When trying to resolve a tax issue, there are often highly-technical issues steeped in substantive tax principles that may steer the outcome. But sometimes there are other ways to resolve tax issues.
The IRS' New Authentication Procedure for Tax Practitioners
By on January 12, 2018
Any tax practitioner who has contacted the IRS after January 3, 2018 to obtain client information has received an unpleasant surprise. The IRS is asking the practitioner to provide his or her social security number and date of birth for authentication purposes. There is no doubt this is an attempt to address security concerns, including concerns about compromised CAF numbers, but the change has caught many in the tax community off guard and led to unpleasant exchanges with IRS personnel.
By on January 3, 2018
On December 20, the Tax Court issued a supplemental opinion in Graev v. Commissioner, in which it reversed its prior position on I.R.C. Section 6751(b) and agreed with the Second Circuit's decision in Chai v. Commissioner. In Chai, the Second Circuit held that Section 6751(b)(1) requires the IRS to obtain written supervisory approval of an initial penalty determination no later than the date the IRS issues the notice of deficiency or files an answer asserting the penalty. A previous blog post discussed the Chai decision and its impact on pending Tax Court cases.