The IRS recently revised Form 2848, Power of Attorney and Declaration of Representative, and instructions. While the instructions to the revised form do not preclude using the prior version of the form, it is recommended that Tax professionals familiarize themselves with the revised form and begin using it. Notable changes to Form 2848 include: Part…
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Groupons…anotheir State Sales Tax Headache
The Groupon and other online voucher sites have created some interesting tax consequences. How much is the sales price and who should pay it? Florida seems to have taken the position that the merchant is responsible for tax on the original price of the goods the purchaser of the voucher is entitled to receive. As…
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Another Exception To Disregarded Entity Treatment
A new exception now has been added to the list. Under final regulations issued under Section 881, the IRS can treat a disregarded entity in a financing structure as a person separate from its owner (that is, as a non-disregarded entity), in determining whether a financing arrangement exists that should be recharacterized under the multiple-party…
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Moving Accounts To Non Complying Banks -2012's Loophole?
Great article by Dick Harvey on FATCA. Will taxpayers defeat FATCA by moving their foreign accounts to foreign banks which don’t care if they can’t sell US securities? They may decide not to cough up the names and SSN’s of their “U.S. persons.” Those banks will be known as NP-FFI’s: non-participating foreign financial institutions. Offshore…
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