Resources Archive
February 13, 2019
Rental Real Estate Under Section 199A Final Regulations...
[ read ]
The Section 199A Final Regulations were released on January 18, 2019 and a corrected version was issued on February 1, 2019, with a few corrections and clarifications.
February 13, 2019
Section 199A Final Regulations Issued on Eve of the 2018 Filing Season...
[ read ]
The Section 199A Final Regulations were released on January 18, 2019 and a corrected version was issued on February 1, 2019, with a few corrections and clarifications. In this blog post I will address some of the key items in the Final Regulations, as clarified, other than rental real estate, which I cover in a separate blog post.
February 5, 2019
Divorce Pleadings May Impact a Request for Innocent Spouse Relief...
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Generally, spouses who file a joint return are subject to joint and several liability for tax deficiencies under the Internal Revenue Code. Yet the IRS may grant a spouse relief from joint and several liability on a joint return in certain circumstances. One mechanism for obtaining relief from the general rule is to seek relief as an "innocent spouse" under 26 U.S.C. Section 6015(f), which authorizes the IRS to grant equitable relief from joint and several liability.
February 4, 2019
Still No Answer on Late Filing Penalty on Electronically Filed Tax Returns...
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In a blog post last year, we discussed the parties' oral arguments in the 5th Circuit Court of Appeal hearing in Haynes v. United States regarding the application of reasonable cause and a late filing penalty to an electronically filed tax return. On January 29th, the 5th Circuit issued an opinion in Haynes vacating the district court's grant of the government's motion for summary judgment and remanded the case to the district court for additional consideration. However, in vacating the lower court decision, the 5th Circuit declined to address the question of whether the U.S. Supreme Court decision in U.S. v. Boyle is still valid law in the age of electronic filing of tax returns.
February 1, 2019
2019 Corpus Christi Chapter/TSCPA Tax Conference... [ read ]
January 31, 2019
New Partnership Audit Rules: Should the Partnership Agreement be Amended?...
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In November 2015, as part of the Bipartisan Budget Act (BBA) of 2015, Congress enacted a new centralized partnership audit regime (PAR) to replace the TEFRA partnership rules. The PAR applies to all partnerships and, like TEFRA, IRS examinations and adjustments will be made at the partnership level. However, unlike TEFRA, the IRS will assess and collect tax from the partnership.
January 30, 2019
Opting Out of the New Partnership Audit Rules...
[ read ]
In November 2015, as part of the Bipartisan Budget Act (BBA) of 2015, Congress enacted a new centralized partnership audit regime to replace the TEFRA partnership rules. The new partnership audit regime applies to all partnerships and, like TEFRA, IRS examinations and adjustments will be made at the partnership level. However, unlike TEFRA, the IRS will assess and collect tax from the partnership.
January 29, 2019
Whitley Penn Houston Conference... [ read ]
January 25, 2019
Tax Law in a Day sponsored by the State Bar of Texas Tax Section... [ read ]
January 25, 2019
The Tax Balancing Act: Minimizing Estate Tax and Maximizing Income Tax Basis...
[ read ]
The lifetime estate and gift tax exemption has risen more than 1600% over the past two decades. In 2017, with an exemption of $5,490,000, there were roughly 5,200 taxable estates but with an exemption of $11,180,000, that tally is expected to fall under 2,000 taxable estates for the 2018 tax year. As fewer estates are subject to federal estate tax, the intersection of estate tax planning and income tax planning is more pivotal than ever before.
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