The U.S. Department of the Treasury today announced that it is engaged with more than 50 countries and jurisdictions around the world to improve international tax compliance and implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target…
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No PAL Exception for Real Estate Held in Trust! — CCA201244017
The main consequence of qualifying as a real estate operator under §469(c)(7) is that §469(c)(2), defining rental activities as per se passive, does not apply for the taxable year to the rental real estate activities of the taxpayer. The substance of §469(c)(7) is best considered in four stages: First, who qualifies as a real…
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Head Up Concerning IRS Correspondence Audits, Compliance Issues and Worker Reclassification
IRS' Commissioner of Self Employed/Small Business Division gave AICPA National Tax conference attendees a heads up on the division's compliance priorities and potential changes. Not surprisingly, he indicated they are shifting more resources to look at more flow-throughs. One issue that has come up in an ongoing study of employment tax returns (among several types…
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Doug Shulman Explains The New & Improved IRS; Before His Retirement
In a few days time – November 11th to be precise – my term as the 47th Commissioner of the Internal Revenue Service officially comes to a close. I suppose it’s quite natural when one has completed a significant task like running the IRS for almost five years to pause ... to reflect on the…
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