News and Tip of the Day


Small Business Taxes & ManagementTM--Copyright 2018, A/N Group, Inc.

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April 18, 2019

News

Victims of the severe storms and flooding that took place on March 12, 2019 in Iowa may qualify for tax relief from the IRS. The Service has added Pottawattamie and Shelby counties to those qualifying. Now, Individuals who reside or have a business in Fremont, Harrison, Mills, Monona, Pottawattamie, Shelby, and Woodbury counties may qualify for tax relief.

The IRS has announced (IR-2019-77) the release of a six-year plan to modernize the agency’s Information Technology systems and improve a variety of taxpayer services critical to the nation’s tax system. The plan outlines a bold strategy to enable business transformation focused on improving services for taxpayers and the tax community while protecting taxpayer data The IRS Integrated Modernization Business Plan is anticipated to cost between $2.3 billion to $2.7 billion over six years through Fiscal Year 2024. Some components of the plan are in place for the current year, and the administration’s budget proposal for Fiscal Year 2020 includes $290 million in funding for the plan. The plan envisions the IRS being able to:

For more information, go to FS-2019-9, IRS Modernization Plan.

Tip of the Day

Negotiating in good faith . . . The negotiations for the business, a long-term contract, etc. may be brutal, but you should still be negotiating in good faith. The seller of a business is asking $700,000. You say you're interested but the price has to come down to $500,000. You haggle over that price and some conditions for six weeks and then abruptly drop your price to $250K without an explanation. That puts the seller in the position of having wasted time and money and the business may be harder to sell since you've taken it off the market. If it can be shown you intended to drop your price all along, you could be sued for negotiating in bad faith and you could be responsible for the other party's costs. Even if you don't have a lawyer working on the negotiations with you, you should have one you're keeping abreast of the situation and ask for advice before major decisions.

 

April 18, 2019

News

Victims of the severe winter storm, straight-line winds, and flooding that took place on March 9, 2019 in Nebraska may qualify for tax relief from the IRS. The Service has updated the list of counties twice since the original release. Now, individuals who reside in or have a business in the counties Antelope, Boone, Boyd, Buffalo, Butler, Burt, Cass, Colfax, Cuming, Custer, Dodge, Douglas, Hall, Howard, Knox, Madison, Nance, Nemaha, Pierce, Platte, Richardson, Saline, Sarpy, Saunders, Stanton, Thurston, and Washington counties, and the Santee Sioux Nation may qualify for tax relief.

The IRS has issued guidance (REG-120186-18 providing additional details about investment in qualified opportunity zones. The proposed regulations allow the deferral of all or part of a gain that is invested into a Qualified Opportunity Fund (QO Fund) that would otherwise be includible in income. The gain is deferred until the investment is sold or exchanged or Dec. 31, 2026, whichever is earlier. If the investment is held for at least 10 years, investors may be able to permanently exclude gain from the sale or exchange of an investment in a QO Fund. Qualified opportunity zone business property is tangible property used in a trade or business of the QO Fund if the property was purchased after Dec. 31, 2017. The guidance permits tangible property acquired after Dec. 31, 2017, under a market rate lease to qualify as “qualified opportunity zone business property” if during substantially all of the holding period of the property, substantially all of the use of the property was in a qualified opportunity zone. A key part of the newly released guidance clarifies the “substantially all” requirements for the holding period and use of the tangible business property. The guidance notes there are situations where deferred gains may become taxable if an investor transfers their interest in a QO Fund.

Tip of the Day

Make money at home? . . . Want to make $500 a day stuffing envelopes at home? Good luck with that. Make money at home schemes, along with a number of others, have been around at least 50 years. Why? Because they continue to work. It used to be ads in magazines, now you're getting them through emails or online in some way. The delivery methods may have changed but there's still one thing in common--they don't work. And worse, you'll probably be out enough cash to hurt.

 

April 17, 2019

News

Talk to your attorney before you run out and dissolve a corporation or other entity. You might want to keep the corporation alive for a while, even if it has no assets. In Timbron International Corporation; Timbron Holdings Corporation (T.C. Memo. 2019-31) the two corporations had their corporate powers and rights suspended by the State of California and were not reinstated until after the deadline for filing a petition with the Tax Court. (The rules very from state to state, but the suspension can be for failure to file tax returns, or even failure to file a $25 annual report.) The Court held that since the corporations lacked the capacity to file a petition in Tax Court. Thus, the Court did not have jurisdiction and dismissed the cases.

Tip of the Day

Sales tax and related parties . . . Most states provide an exemption for sales of property to a related party. For example, the transfer of a car from a father to his daughter. How far the exemption goes depends on the state--most are limited to immediate family. Transfers to another entity such as from a shareholder to a corporation aren't as universal. Most states do provide an exemption where assets are transferred on the initial incorporation (e.g., where a taxpayer contributes assets in exchange for stock in the corporation) or startup of a partnership.

 

April 16, 2019

News

Travel expenses are deductible if you're away from your tax home. For example, you live in Boston and spend two weeks on a consulting job in San Francisco. Airfare, lodging, etc. are deductible. But if that consulting job is basically full-time for 14 months, your tax home becomes San Francisco and the travel is no longer deductible. (This is a complex area; check the rules carefully.) In Michael E. Brown and Miriam L. Mercado-Brown (T.C. Memo. 2019-30) the taxpayer was an independent contractor carrying on a "concierge CFO business". He has had three clients simultaneously, but he entered into a three-year contract with Co. X and was required to work four days a week in Pennsauken, New Jersey. He returned to his home in Atlanta, Georgia, for the rest of the week. Company X was the taxpayers' sole source of income for the years at issue. The IRS disallowed the taxpayer's deductions for his traveling expenses between Atlanta and Pennsauken for two years. The Court noted that even though the contract could be terminated, the taxpayer could not have expected the assignment to be concluded within a reasonably short period. The Court sided with the IRS in denying the travel expenses. The Court also allowed the accuracy-related penalty noting the taxpayer was a CPA with a master's degree in finance and prepared his own tax return. The Court said his experience and training should have alterted him to the dubiousness of his reporting position.

Tip of the Day

Don't throw those files in the closet . . . If your tax return is filed, don't put the files away just yet. If you haven't done so already, this is a good time to review investments, analyze how your rental properties or other investments are working for you, etc. Clearly, you should do it more frequently than once a year, but if you don't do it quarterly, now is a good time. Then, before putting them away, decide on your retention period. Some only need to be save four years; records showing basis in assets should be saved until four years after you file the return disposing of the asset. Now is also a good time to see what old documents you can shred. If in doubt, ask your accountant.

 

April 15, 2019

News

The IRS announced (IR-2019-17) the results of a national two-week education and enforcement campaign to combat employment tax crimes featuring visits to nearly 100 businesses showing signs of potential serious noncompliance and taking several dozen legal actions against suspected criminals.

The IRS's Whistleblower Office denied the petitioner's whistleblower award claim under Sec. 7623(b). After the petitioner filed a petition challenging the IRS's decision, the IRS filed a motion to remand this case to the Whistleblower Office for further consideration. The petitioner objected to the granting of the IRS's motion. The Tax Court held in appropriate circumstances this Court may remand a whistleblower case to the Whistleblower Office. The Court further held that because (1) the IRS has identified substantial and legitimate concerns that support a remand, (2) remand will conserve the Court's and the parties' time and resources, and (3) the petitioner will not be unduly prejudiced, the IRS's motion to remand was granted. (Whistleblower 769-16W 152 T.C. No. 10)

Tip of the Day

Times up . . . Put down your pens and pencils. If you're still working on your return and it's a complicated one, consider an extension. Doing so will give you more time to put it aside and review it in detail in a couple of days. An extension will not increase your chances of an audit. You should be sure you're fully paid to avoid any late payment penalties. You should also file an extension if you're missing information like a K-1, 1099, etc.

 

April 12, 2019

News

The IRS has issued guidance (Rev. Proc. 2019-18) today that provides a safe harbor allowing professional sports teams to treat certain player and staff-member contracts and draft picks as having a zero value for determining gain or loss to be recognized on the trade of a player or staff-member contract or a draft pick. Historically it has been difficult for professional sports teams to assign a monetary value to contracts or draft picks due to the fluctuating nature of the performance of players and staff members, and market conditions. This guidance allows professional sports teams to avoid having to value their player contracts, staff-member contracts, and draft picks to determine the amount of any gain or loss to be recognized. A team using the safe harbor recognizes gain only if cash is received in the trade.

Tip of the Day

Can't pay? . . . You're not the first taxpayer to be caught short on April 15. The first thing to do is either file your return (if you're done) or file an extension and pay whatever you can. There are two penalties--one for not filing on time and one for not paying on time. The failure to file on time penalty is by far the larger. If you're filing a return (rather than an extension) you can pay by credit card or request an installment agreement (Form 9465). The instructions to Form 9465 aren't that complicated. An IRS installment agreement is cheaper than paying interest on a credit card, but it can have some drawbacks. Your tax software may complete much of the installment agreement form. What about the state? All that we know allow credit cards. Installment payments for paying with the return vary. Most states have penalties that follow the IRS. But be careful. Check the rules for penalties.

 

April 11, 2019

News

The full House has approved the Taxpayer First Bill of 2019 (HR 1957). The bill has both bipartisan and Senate support so it stands a good chance of passage in the Senate. The bill would make important changes to the operation of the IRS and is supported by the AICPA.

If the IRS has issued an assessment it has 10 years to enforce payment. In Mary Carol S. Johnson; James W. Smith, Defendants - Appellees / Cross-Appellants, and Marian S. Barnwell; Billie Ann S. Devine; Eve H. Smith, Defendants (U.S. Court of Appeals, Tenth Circuit) the IRS sought to enforce a claim for estate taxes. The appellees argued that state (Utah) law has a six-year statute of limitations on such claims. The IRS argued that the Supreme Court has held that “the United States is not bound by state statutes of limitation . . . in enforcing its rights,” even if the suit is brought in state court. The Court held the IRS could collect on its claim. The Court also held that the running of the period of limitations for collection of any tax imposed shall be suspended for the period of any extension of time for payment granted. In this case the estate had elected to defer payment of the tax under Sec. 6166.

Tip of the Day

Direct deposit . . . There will be a deluge of returns hitting the IRS within the next few days. If you're just filing now you can speed up your refund by requesting a direct deposit of the any refund. The same approach often works for state returns.

 

April 10, 2019

News

The IRS and the Security Summit partners have announced (IR-2019-66) new results from 2018 that show major progress in the fight against tax-related identity theft. Since forming the Security Summit in 2015, the IRS, state tax agencies and the private-sector tax industry enacted joint initiatives, many invisible to taxpayers, that have resulted in fewer fraudulent tax returns entering tax processing systems, fewer confirmed identity theft returns being stopped, fewer bad refunds being issued and fewer Americans identifying themselves as victims of tax-related identity theft. The number of taxpayers reporting identity theft has dropped from 677,000 in 2015 to 199,000 in 2018. The release goes on to say not every aspect of the problem is positive. Identity thieves are changing targets and aiming at businesses and tax professionals. Because of the efforts of the IRS and Security Summit Partners, thieves need more information to impersonate a taxpayer and tax professionals can provide that.

You may be able to avoid an accuracy-related or gross valuation misstatement penalty if you can show you reasonably relied on a professional such as a CPA or appraiser. In Alan H. Ginsburg (U.S. District Court, M.D. Florida) the petitioner sought a refund of the gross valuation misstatement penalty and related interest claiming reliance on a professional advice. But the Court noted for reliance on a professional's advice to be reasonable, the taxpayer must show that: (1) “the advice was based on all pertinent facts and circumstances and the law as it relates to those facts and circumstances”; (2) the advice was not based on any “unreasonable factual or legal assumptions”; and (3) “it was objectively reasonable for the taxpayer to rely on that advice.” Reliance is not reasonable if the adviser was a promoter of the transaction or otherwise had a conflict of interest which the taxpayer knew or should have known about. Similarly, reliance on professional advice is unreasonable if the taxpayer “knew or should have known that the transaction was ‘too good to be true’” based on all the circumstances. Here the taxpayer relied on advice from the promoter or his agent, or, in the case of one professional, he did not have all the pertinent facts and circumstances. The Court also noted that the taxpayer should have known the transaction was too good to be true, and, therefore, his reliance on professional advice was unreasonable. The Court denied the refund claim.

Tip of the Day

Not much time left . . . If you haven't started on your return by now and you've got a complicated financial life, now would be a good time to do so. There isn't much time left. The deadline is Monday (the 15th). You'll get a break if you live in Massachusetts or Maine or come under one of the exceptions to the April 15 deadline. But waiting much longer could be dangerous. You could find yourself missing a vital piece of information or having to pay and not having the cash in the bank. Get your documents in order, buy your tax software if you haven't done so already, and get to work. Even if you plan to file an extension, you'll need a good estimate of your tax liability to determine how much, if anything, you'll owe. Some taxpayers have had big surprises, so be aware. Chances are it'll take you longer this year to prepare your return. In addition to changes in the tax law and the accompanying software, there are new questions you might have to deal with.

 

April 9, 2019

News

The IRS has released the second quarter update to the 2018-2019 Priority Guidance Plan. The 2018-2019 Priority Guidance Plan contains guidance projects that we hoped to complete during the twelve-month period from July 1, 2018, through June 30, 2019 (the plan year).

Tip of the Day

Basis in property received as a gift . . . The basis of property you inherit is the fair market value (FMV) on the death of the deceased. But your basis in property you receive as a gift is generally the donor's basis. Thus, if uncle Fred leaves you his 1965 Corvette in original condition he bought new and you sell it for $65,000, you're going to have a big gain because he probably only paid a few thousand dollars. But if the FMV of the property is less than the donor's adjusted basis at the time of the gift, your basis depends on whether you have a gain or loos when you dispose of the property. This can be tricky. It might be best to talk to you tax adviser.

 

April 8, 2019

News

Almost any activity could be classified by the IRS as a not-for-profit one and losses denied. But there are some that the IRS is quicker to pounce on than others. In Charles M. Steiner and Rhoda L. Steiner (T.C. Memo. 2019-25) the taxpayers had a 155-foot motoryacht they decided to charter. The boat had a full-time captain and crew. They paid some $4.6 million for the boat in 2001 and refitted it between 2006 and 2009 at a cost of $10.8 million. Until 2009 the boat was used for personal purposes. The decision to charter the boat at the same time they decided to sell the boat. In 2011 the gross receipts from the boat $164,700, reduced by $113,700 of cost of goods sold. Expenses deducted were $757,000; for 2012, the year the boat sold, it generated no income but expenses amounted to $122,000. The Court looked at the nine factors generally examined in hobby loss situations and found only one factor in the taxpayer's favor. Ironically, the one factor that favored the taxpayers was personal pleasure or recreation, because their was no indication they derived recreationor pleasure from the charter activity. The taxpayers had used the boat for personal purposes until 2010. One factor examined was the expertise of the taxpayer or advisors. The taxpayer did rely on advisors, but those advisors were charter companies who stood to profit from the taxpayers' entry into the charter business. The Court found the taxpayers' reliance on these experts as unreasonable. The Court also found that he did not use his expertise from operating a sucessfull business in the charter activity. The Court sided with the IRS in denying the losses.

Tip of the Day

Joint or separate? . . . If you're married will you be better off filing joint or separate? It's a common question. Generally, a couple is better off filing joint, but there are some situations where that's not true. Fortunately, if you do your return on a computer, and you've attributed the income and deductions to the proper spouse, you should be able to select a report that does the comparison automatically. There is one important reason for filing married, separate. By doing so each spouse is responsible for their own liability.

 

April 5, 2019

News

The IRS is reminding U.S. citizens and resident aliens, including those with dual citizenship, that if they have a foreign bank or financial account, April 15, 2019, is the deadline to file their annual Report of Foreign Bank and Financial Accounts (FBAR). They should also check to see if they have a U.S. tax liability and a federal tax return filing requirement. The deadline for filing the FBAR is the same as for a federal income tax return. This means that the 2018 FBAR, Form 114, must be filed electronically with the Financial Crimes Enforcement Network (FinCEN) by April 15, 2019. FinCEN grants filers missing the April 15 deadline an automatic extension until Oct. 15, 2019, to file the FBAR. Taxpayers don’t file the FBAR with individual, business, trust or estate tax returns. Taxpayers who want to paper-file their FBAR must call the Financial Crimes Enforcement Network’s Regulatory Helpline to request an exemption from e-filing. For more information, go to FS-2019-17 and Report of Foreign Bank and Financial Accounts (FBAR).

The Treasury Inspector General for Tax Administration (TIGTA) did a review to provide selected information related to the IRS’s 2019 Filing Season. TIGTA plans to issue the final results of our analysis later in Calendar Year 2019. The Tax Cuts and Jobs Act of 2017 enacted the first major tax reform legislation in more than 30 years, significantly affecting the filing of tax returns during the 2019 Filing Season. In addition to the passage of the Tax Cuts and Jobs Act of 2017, the IRS is implementing a redesigned Form 1040, U.S. Individual Income Tax Return. Further complicating the filing season, there was a partial Government shutdown that lasted 35 days, beginning on December 22, 2018, and ending January 25, 2019. To see the complete report, go to www.treasury.gov/tigta/auditreports/2019reports/201944030fr.pdf.

The major changes in the tax law have along with lower withholdings (based on the new law) has left more than a few taxpayers owing additional amounts on their return this year. As a result, the IRS is again advising taxpayers about adjusting their withholdings or making quarterly estimated payments. The IRS has provided a number of resources--FS-2019-6, Basics of Estimated Taxes for Individuals and IR-2019-62. The second publication contains links to YouTube videos, Form 1040-ES, Estimated Tax for Individuals, and Publication 505, Tax Withholding and Estimated Tax.

Tip of the Day

Estimated tax points . . . Some people need to make estimated payments because of multiple incomes, some because of capital gains, some because of business income. It's not nearly as difficult as it sounds, at least to get a ballpark figure. The easiest approach is to go to the tax software you used to prepare the return. Most software packages have a section where you can calculate 2019 taxes. You can put in some adjustments, e.g., you expect a big capital gain from the sale of that empty lot you own but all your other information will remain the same, and let the program compute any additional tax. Or you can go into the federal estimate section and follow the instructions and the program will compute the quarterly estimated payments and complete the vouchers. You may also have to make estimated payments for state purposes.

 

April 4, 2019

News

The two bills mentioned in our April 3 News section, Taxpayer First Bill of 2019 (HR 1957) and the Setting Every Community Up for Retirement Enhancement (SECURE) Bill (HR 1994) have been reported out of the House Ways and Means Committee. Because Senate Finance Committee Chairman Chuck Grassley (R-Iowa) is on board, the bills stand a good chance of making it through both houses.

Revenue Procedure 2019-17 (IRB 2019-17) provides guidance regarding the general public use requirements for qualified residential rental projects financed with tax-exempt bonds under Sec. 142(d). Specifically, it coordinates these requirements with the provisions in Sec. 42(g)(9). Under Sec. 42(g)(9), a project does not violate the general public use requirement under Sec. 42 as a result of specified occupancy restrictions or preferences (for example, certain housing preferences for military veterans).

Tip of the Day

Retirement savings credit . . . More than a few tax benefits are phased out as a taxpayer's income increases. As a result, many taxpayers don't even think about some of the credits, assuming their income will never be low enough to qualify. Then they encounter a downturn in their business or the loss of a spouse's income, etc. One of the lesser-known credits is the Credit for Qualified Retirement Savings Contributions. On the lower range of the AGI scale, the credit could be as much as 50 percent of the contribution based on no more than a $2,000 contribution The credit decreases as your income goes up and is phased out completely at an AGI of $63,000 for a married couple. Both you and your spouse could qualify. While it applies to other plans, assume you contribute $3,000 to a deductible IRA. The maximum contribution that qualifies for the credit is $2,000. You're filing a joint return and have AGI of $30,000. The credit percentage is 50 percent. Your credit is $1,000. You could get a $3,000 deduction and a $1,000 credit. It could be one of the very few giveaways in the tax law.

 

April 3, 2019

News

Two bipartisan bills have been scheduled for markup by the House Ways and Means committee. The first would make reforns in the IRS including an independent appeals office, provided additional protection for taxpayers from tax ID theft, make changes to the private debt collection program and modernize the IRS' technology systems. The second bill would expand retirement savings in a number of ways. The bill would:

Tip of the Day

Start-up costs . . . They're generally not deductible, but you can amortize them over a period of 180 months. The costs can be grouped as investigatory, business start-up, and preopening. Investigatory is exactly what it sounds like--analyzing markets, scouting a location, etc. Start-up expenses include expenses such as initial hiring, marketing such as designing an ad program, securing vendors, etc. Preopening expenses might include labor to stock shelves. Where the expenses fall doesn't matter as much as that expenses before the start of business aren't currently deductible. The start-up phase is over (and you can expense most expenditures currently) when you're open for business. In a retail environment that would mean the day you unlock the door and invite customers in, even if you don't make a sale that day. The law provides an exception to the rule that you have to capitalize these expenses. You can expense the first $5,000 if your total start-up expenses are less than $50,000. The $5,000 allowance is phased out if the total costs are between $50,000 and $55,000.

 

April 2, 2019

News

The IRS has withdrawn a notice of proposed rulemaking (REG-124627-11; NPRM REG-124627-11) that would have provided guidance on how to determine whether certain transactions satisfy the continuity of interest (COI) requirement under Sec. 1.368-1(e), applicable to certain corporate reorganizations described in Section 368 of the code. The proposed regulations being withdrawn would have affected corporations and their shareholders.

In Jon Robert Ludlam and Maria Louisa Ludlam (T.C. Memo. 2019-21) the Tax Court found no abuse of discretion by a settlement officer in sustaining the filing of a notice of Federal tax lien (NTFL) and in denying a face-to-face collection due process hearing. The settlement office had granted additional time to provide documentation and the taxpayers refused to propose collection alternatives or financial information.

Tip of the Day

Charitable contributions under the new law . . . There wasn't a big change in the rules for charitable contributions, but you should now be extra careful to keep good documentation. A significantly fewer number of people will be itemizing because of the $10,000 cap on taxes and this disallowance of most miscellaneous deductions and casualty losses. That will free up the IRS to look at other issues and charitable contributions could be high on the list. Of course, the IRS could cut staff equalizing the change. The IRS could also concentrate on other issues such as rental losses. Best advice? Keep good documentation.

 

April 1, 2019

News

Revenue Ruling 2019-11 (IRB 2019-17) provides guidance to taxpayers regarding the inclusion in income of recovered state and local taxes in the current year when the taxpayer deducted state and local taxes paid in a prior year, subject to the Section 164(b)(6) limitation.

In the taxpayer's chapter 11 bankruptcy proceeding, upon the agreement of the taxpayer and the IRS, the bankruptcy court entered a consent order resolving the IRS' objection to the plan of reorganization that settled the amount of the IRS' priority claim and set out procedures for resolving the IRS' unsecured general claim (consent order). After the plan of reorganization was confirmed, the IRS moved for leave to amend its proof of claim because it determined that the taxpayer might owe additional prepetition taxes. That motion was denied by the bankruptcy court. Later, but while the bankruptcy case was still pending, the IRS issued a notice of deficiency for certain of the years covered by the consent order and the plan of reorganization, and the taxpayer petitioned for redetermination. The taxpayer has moved for summary judgment that the consent order bars the IRS from pursuing any additional deficiency for the tax years covered in the consent order. The Tax Court held that a bankruptcy court order that does not determine a taxpayer's total Federal tax liability for a given tax year, but only resolves the amount of the IRS' claim to be paid by the bankruptcy estate pursuant to the plan of reorganization, does not preclude a subsequent notice of deficiency (or resulting tax proceeding) for nondischargeable taxes from the same tax year. In addition, because the bankruptcy court did not determine the taxpayer's total Federal tax liability for any of the subject tax years, res judicata and collateral estoppel do not bar the IRS from pursuing additional deficiencies for the subject tax years. Charles K. Breland, Jr. (152 T.C. No. 9)

Tip of the Day

Ballpark first . . . Before you send your family into the sofa cushions, the basement and the glove boxes of the cars for medical receipts, take a few minutes to work through some numbers. Your deduction for real estate, state and local income taxes, and other taxes is limited to $10,000. That means you'll need another $14,000 of additional deductions to save taxes by itemizing. (If you're married your standard deduction is $24,000 (more if your over 65 and/or blind).) If you have a mortgage, you could easily break that threshold, or come pretty close. Now look at medical expenses. There's a 7.5 percent floor. In other words, if your adjusted gross income (AGI) is $100,000 you'll need $7,500 in expenses before the first dollar is deductible. Pay your own health insurance? You'll probably break it easily. If you don't have a mortgage, and not much in charitable contributions, you'll need $14,000 in medical expenses--over and above the $7,500. That's a total of $21,500. Put some good guesses into your tax software and see if you break the standard deduction. If you're close, time to go dumpster diving, round up your receipts, and refine those numbers. If you're not there's no reason to add up all those $10 copays, the $400 dentist visit and the $200 for eyeglasses. Obviously, if your income is higher, the floor goes up. If your income was only $50,000, the floor is lower--$3,750. Keep in mind that if you're single your standard deduction is lower, so there's a greater chance you'll be better off by itemizing.

 

March 29, 2019

News

The IRS has withdrawn a notice of proposed rulemaking (REG-143686-07) containing proposed regulations under numerous sections of the Code. The proposed regulations being withdrawn would have provided guidance on the recovery of stock basis in distributions of property made by a corporation to a shareholder and certain transactions treated as dividend-equivalents, as well as guidance regarding the determination of gain and the basis of stock or securities received in certain transactions. The proposed regulations being withdrawn would have affected shareholders and security holders of corporations.

Revenue Procedure 2019-15 (IRB 2019-14) provides a waiver for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2019-15 adds the Democratic Republic of the Congo, Cuba, Iraq, and Nicaragua to the list of waiver countries for tax year 2018 for which the minimum time requirements are waived.

Notice 2019-24 (IRB 2019-14) provides for adjustments to the limitation on housing expenses for purposed of Section 911 of the Code. These adjustments are made on the basis of geographic differences in housing costs relative to housing costs in the United States. Further, if the limitation on housing expenses is higher for taxable year 2019 than the adjusted limitations on housing expenses provided in Notice 2018-44, qualified taxpayers may apply the adjusted limitations for taxable year 2019 to their 2018 taxable year.

Tip of the Day

Sold your home? . . . The new law hasn't changed the rules here. You can exclude $250,000 of the gain ($500,000 if married filing joint) of the gain if you owned and used the home as your principal residence for 2 out of the last five years (there are exceptions and fine points here; check the rules). But you could still have a gain after the taxable exclusion amount, particularly if you're single or your spouse passed away. You can add to the contract purchase price the cost of additions and improvements (see our Checklist) and many expenses that weren't deductible when your originally purchased the property. That includes abstract fees, legal fees associated with the purchase, recording and survey fees, transfer or stamp taxes and owner's title insurance. From the selling price subtract sales commissions, advertising fees, legal fees, other costs and fees to sell the property.

 

March 28, 2019

News

The IRS has released the 2019 version of Form 941 and the accompanying instructions for Form 941. (Also released are the versions for Puerto Rico and American Samoa, Guam, the Commonwealth of the Northern Mariana Islands and the U.S. Virgin Islands.) The IRS has also released updated versions of Publication 505, Tax Withholding and Estimated Tax and Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities.

Notice 2019-22 credit phase-out schedule for new qualified plug-in electric drive motor vehicles sold by General Motors, LLC. Section 30D provides for a credit determined under Sec. 30D(b) for certain new qualified plug-in electric drive motor vehicles. The new qualified plug-in electric drive motor vehicle credit begins to phase out for a manufacturer’s qualified plug-in electric drive motor vehicles in the second calendar quarter after the calendar quarter in which at least 200,000 of the manufacturer’s vehicles that qualify for the credit have been sold for use or lease in the United States (determined on a cumulative basis for sales after December 31, 2009). General Motors, LLC has submitted quarterly reports that indicate that its cumulative sales of qualified plug-in electric drive motor vehicles reached the 200,000-vehicle limit during the calendar quarter ending December 31, 2018. Accordingly, the credit for all new qualified plug-in electric drive motor vehicles sold by General Motors, LLC will begin to phase out on April 1, 2019.

Tip of the Day

Casualty gain . . . The rules for casualty losses have changed. You can now only deduct a personal casualty loss if in a federally declared disaster. Business losses are unaffected by the law change. But you can have a casualty gain. For example, your vacation home burns to the ground. You paid $75,000 for the house 30 years ago. The insurance company pays you the replacement cost, $500,000. You decide not to replace the property. You'd have a taxable gain of $425,000. If you had built a replacement home (or purchased one) for at least $500,000, you postpone any gain. If you replaced the property, but did not spend the full $500,000, you'd have to report a partial gain. The same rules apply to business casualties. You generally have two years from the date of the loss to replace the property and postpone any gain. Things can get complicated quickly and the dollar amounts are often significant. Get good advice.

 

March 27, 2019

News

Five tables presenting data for all individual income tax returns that reported noncash charitable contributions for Tax Year 2016 on Form 8283, Noncash Charitable Contributions, are now available on SOI's Tax Stats Web page. These tables are also based on data reported on Form 1040, U.S. Individual Income Tax Return, and Schedule A, Itemized Deductions. The data detail the number of returns, number of donations, donor's cost, fair market value, and amount carried to Schedule A. Data are categorized by donation type, donee type, size of adjusted gross income, and donor age.

The IRS has issued proposed regulations (REG-135671-17) to amend final regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner or certain related entities. These regulations affect partnerships and their partners.

The IRS has issued final regulations (T.D. 9853) that provide guidance regarding the amount of the penalty under Section 6707A of the Code for failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction. The final regulations are necessary to clarify the amount of the penalty under Section 6707A, as amended by the Small Business Jobs Act of 2010. The final regulations will affect any taxpayer who fails to properly disclose participation in a reportable transaction.

The IRS has issued proposed regulations (REG-121694-16) under Section 301 of the Code. The proposed regulations would update existing regulations under Section 301 to reflect statutory changes made by the Technical and Miscellaneous Revenue Act of 1988, which changes provide that the amount of a distribution of property made by a corporation to its shareholder is the fair market value of the distributed property. The proposed regulations would affect any shareholder who receives a distribution of property from a corporation.

Tip of the Day

Check tax credit requirements . . . The IRS has a special Due Diligence Checklist (Form 8867) to be completed by tax preparers for when the earned income tax credit, child tax credit, additional child tax credit, other dependent tax credit, American opportunity tax credit, or head of household status is claimed on the return. It seems more than probable the extra task put on preparers is because the IRS has found more significant errors associated with the credits and head of household status. If you're preparing your own return you should check the requirements for these tax benefits carefully. These items could be an audit trigger.

 

March 26, 2019

News

Victims of the severe storms and flooding that took place on March 12, 2019 in Iowa may qualify for tax relief from the IRS. The President has declared that a major disaster occurred in the State of Iowa. Following the recent disaster declaration for individual assistance issued by the Federal Emergency Management Agency, the IRS announced today that affected taxpayers in certain areas will receive tax relief. Individuals who reside or have a business in Fremont, Harrison, Mills, Monona and Woodbury counties may qualify for tax relief. The declaration permits the IRS to postpone certain deadlines for taxpayers who reside or have a business in the disaster area. For instance, certain deadlines falling on or after March 12, 2019 and before July 31, 2019, are granted additional time to file through July 31, 2019. This includes 2018 individual income tax returns and payments normally due on April 15, 2019. It also includes the quarterly estimated income tax payments due on April 15, 2019 and June 17, 2019. Eligible taxpayers will also have until July 31, 2019 to make 2018 IRA contributions. In addition, penalties on payroll and excise tax deposits due on or after March 12, 2019, and before March 27, 2019, will be abated as long as the deposits were made by March 27, 2019. For more information, go to Tax Relief for Iowa Flood and Storm Victims.

Victims of the severe winter storm, straight-line winds, and flooding that took place on March 9, 2019 in Nebraska may qualify for tax relief from the IRS. The President has declared that a major disaster occurred in the State of Nebraska. Following the recent disaster declaration for individual assistance issued by the Federal Emergency Management Agency, the IRS announced today that affected taxpayers in certain areas will receive tax relief. Individuals who reside or have a business in Butler, Cass, Colfax, Dodge, Douglas, Nemaha, Sarpy, Saunders, and Washington counties may qualify for tax relief. The declaration permits the IRS to postpone certain deadlines for taxpayers who reside or have a business in the disaster area. For instance, certain deadlines falling on or after March 9, 2019 and before July 31, 2019, are granted additional time to file through July 31, 2019. This includes 2018 individual income tax returns and payments normally due on April 15, 2019. It also includes the quarterly estimated income tax payments due on April 15, 2019 and June 17, 2019. Eligible taxpayers will also have until July 31, 2019 to make 2018 IRA contributions. In addition, penalties on payroll and excise tax deposits due on or after March 9, 2019, and before March 25, 2019, will be abated as long as the deposits were made by March 25, 2019. For more information, go to Tax Relief for Nebraska Victims of Severe Winter Storm and Flooding.

The 2019 revision of Form 656-Booklet, Offer in Compromise (OIC) is available for download on IRS.gov, Monday, March 25. The booklet contains current forms and instructions for submitting an OIC. Using previous versions of the booklet may result in delayed processing of OIC applications.

Tip of the Day

Casualty losses . . . Personal casualty losses are no longer allowed. Have a kitchen fire that cost you $25,000 and not covered by insurance? The loss isn't deductible. However, if the loss is related to a federally declared disaster, the loss is deductible. Losses related to a business casualty are still deductible under the old rules. Thus, if the barn you store you farm tractors in burns, that loss would be deductible. Casualty losses can be tricky and the dollar amounts significant. Check with a tax professional.

 

March 25, 2019

News

The IRS has released filing statistics for the week ended March 15, 2019. Total returns received are down 2.5 percent from 2018, returns processed are down 2.4 percent. To date, 75.9 million returns have been filed. Returns filed by professionals are down 3.6 percent; self-prepared returns are up 1.3 percent. The number of refunds are down 3.0 percent (probably a result of less returns filed); the amount is down 3.1 percent, but the average refund is down only 0.1 percent.

The IRS will provide a free online, web-based information session Thursday, March 28, 2019, on how to do a Paycheck Checkup using the IRS Withholding Calculator. A Paycheck Checkup can help employees see if they’re withholding the right amount of tax from their paychecks. Too little could mean an unexpected tax bill or penalty. Taxpayers with more complex situations, such as those making estimated tax payments, might need to use Publication 505, Tax Withholding and Estimated Tax, instead of the calculator. For example, this includes people who owe self-employment tax, the alternative minimum tax, or tax on unearned income from dependents, and people with capital gains or dividends. You can register for the Webinar at Understanding How to Do a Paycheck Checkup--2019.

Tip of the Day

Qualified business income deduction . . . The 20-percent deduction applies to income from a S corporation, partnership, and a sole proprietorship. If you're using a tax program, the software should, in most cases, take care of the details. But there may be additional information you have to enter on the input schedule for the K-1 for your Form 1040 including W-2 wages and the unadjusted basis of qualified property. In addition to the businesses mentioned above, dividends from REITs and publicly traded partnership income (PTP) also qualify for the 20-percent deduction. The deduction will appear on line 9 of Form 1040. It can get complicated, so work through the numbers carefully.

 

March 22, 2019

News

Section 355(a)(1) provides that, if certain requirements are met, a corporation may distribute stock and securities of a controlled corporation to its shareholders and security holders without recognition of gain or loss or income to the recipient shareholders or security holders. Among those requirements, both the distributing corporation and the controlled corporation must be engaged in an active trade or business (ATB) immediately after the distribution. Sections 355(a)(1)(C) and (b), and Reg. Sec. 1.355-3(a)(1)(i). Each trade or business must have been actively conducted throughout the five-year period ending on the date of the distribution. Revenue Ruling 2019-09 (IRB 2019-14) suspends Rev. Rul. 57-464 and Rev. Rul. 57-492, pending the completion of a study by the Department of the Treasury and the Internal Revenue Service (Service) regarding the ATB requirement under Sections 355(a)(1)(C) and (b) of the Code.

Tip of the Day

Schedule C and material participation . . . Schedule C of Form 1040 contains a question (G, just above Part I) asking whether or not you materially participated in the business in 2018? You've got to check either the yes or no box. For most sole proprietors, the question is an easy yes or no. If this is your sole source of income, the answer is probably yes, but check the definition of material participation on page C-4 of the instructions to Schedule C. If the business was managed by someone else and you participated 500 hours or less during the year, chances are you did not materially participate. But you may qualify under one of the other definitions so check the instructions. Time your spouse spent working in the business counts, even if its your business. This can be a tricky area and the consequences are significant. If you didn't materially participate and you have a loss, the loss will be one from a passive activity and you won't be able to deduct it currently.

 

March 21, 2019

News

When sending out a notice of deficiency the IRS's responsibility is limited to sending it to the taxpayer's last known address. That's important because the mailing of the notice starts the time period you have for challenging the deficiency and for other purposes. In Damian K. Gregory and Shayla A. Gregory (152 T.C. No. 7) the taxpayerss moved. After they moved, they filed their joint 2014 Federal income tax return using their old address. During an examination of their 2014 return, the taxpayers submitted Forms 2848, Power of Attorney and Declaration of Representative, showing their new address. While the examination was ongoing, the taxpayers submitted a Form 4868, Application for Automatic Extension of Time To File U.S. Individual Income Tax Return, also showing their new address. The IRS mailed a notice of deficiency to them at their old address. They filed an untimely petition. The IRS moved to dismiss the petition for lack of jurisdiction, arguing that they their filing was not timely. They moved to dismiss for lack of jurisdiction, arguing that the IRS failed to send the notice of deficiency to their last known address. The Court noted that a notice of deficiency provides sufficient notice if sent to the taxpayer's last known address. A taxpayer's last known address is the address shown on the most recently filed and properly processed return unless updated by clear and concise notification of a different address. The Court held that Form 2848 does not constitute a return for purposes of updating a taxpayer's last known address and that it does not constitute clear and concise notification of a different address. Similarly, the Court held that Form 4868 does not constitute a return for purposes of updating a taxpayer's last known address and Form 4868 does not constitute clear and concise notification of a different address. The Court held that the IRS's notice of deficiency was sufficient because it was sent to the taxpayers' last known address. (To be on the safe side, use Form 8822, Change of Address, or, for a business, Form 8822-B, Change of Address or Respoonsible Pary-Business)

Tip of the Day

Gain on tax-exempt bonds not tax exempt . . . The interest income on municipal bonds is generally tax exempt for federal purposes. (Whether or not it's taxable for state purposes depends on the rules in your state and who issued the bonds.) But any gain on the sale or redemption of the bonds is fully taxable. Likewise, any loss is deductible, the same as other short or long-term capital losses.

 

March 20, 2019

News

There was a drafting error in the Tax Cuts and Jobs Act that resulted in the loss of the rapid writeoff for qualified improvement property (QIP). Under the new law improving the interior of a retail store or restaurant, modernizing common areas in office buiildings, etc. must now be depreciated over 39 years. A bipartisan bill has been introduced that, if passed, will remedy the situation.

The Tax Cuts and Jobs Act of 2017 introduced Sec. 199A, which provides individuals with a new tax deduction for qualified business income. Section 199A provides a deduction of up to 20 percent for an individual’s domestic qualified business income from their taxable income. The IRS estimates that almost 23.7 million taxpayers may be eligible to claim the deduction. In addition, the Joint Committee on Taxation estimates a reduction in tax from this provision of $27.7 billion in Fiscal Year 2018 and $47.1 billion in Fiscal Year 2019, and totaling $414.5 billion over Fiscal Years 2018 through 2027. The Treasury Inspector General for Tax Administration (TIGTA) performed a review as part of its overall audit strategy assessing the IRS’s implementation of the Tax Cuts and Jobs Act. TIGTA performed this separate review of the IRS’s implementation of the Section 199A Qualified Business Income Deduction because of its complexities and impact on taxpayers. TIGTA found the IRS took proactive steps to implement the Qualified Business Income Deduction including establishing an implementation team, creating an action plan, and developing a communication strategy. However, IRS management indicated that due to the timing of the release of guidance, the IRS was unable to develop a tax form for the deduction. IRS management indicated that delaying the development of a tax form until Tax Year 2019 allowed the IRS to receive comments on the guidance, consider those comments before finalizing the guidance, and gain some experience with the first filing season. As an alternative, the IRS developed a worksheet to assist taxpayers with calculating the Qualified Business Income Deduction. TIGTA's report can be seen at www.treasury.gov/tigta/auditreports/2019reports/201944022fr.pdf.

In a 2018 decision, Norma L. Slone, et al. (U.S. Court of Appeals, Ninth Circuit), the Court held the former shareholders of a corporation knew that the buyers had no intention of paying the taxes and that the transaction lacked economic substance. The Court found that under state law the transfer was fraudulent and the shareholders were responsible for the tax. The U.S. Supreme Court has denied the petitioner's petition for certiorari, letting the Court of Appeals decision stand.

Tip of the Day

Federal/state differences . . . Interest income from federal obligations such as U.S. Treasury bonds are fully taxable for federal purposes, but exempt for state purposes. On the other hand, municipal bond interest is generally exempt for federal purposes, but may or may not be taxable for state purposes. Interest on bonds of your home state are usually exempt; those of other states, aren't. Interest on bonds of the Commonwealth of Puerto Rico are generally exempt at the state level. The theory here is straightforward. The actual mechanics may not be. If you invested in a tax exempt mutual fund, the fund will have to give you the percentage of income for the year that is tax exempt in your state. That may be included the mailing from the fund or broker. If it isn't, you'll have to do some digging by calling or going to the fund's website. Then be careful how you enter the data in your tax software.

 

March 19, 2019

News

The Federal Insurance Contributions Act tax is imposed on both employees and employers to fund Social Security and Medicare. Most employers withhold the Social Security tax from employees’ wages and pay it to the IRS on the employees’ behalf. Individuals with more than one employer and whose combined Social Security tax withholding from all employers exceeds the maximum annual withholding amount may claim the excess amount of Social Security tax withheld as a refundable credit. As of December 28, 2017, the IRS received more than 1.5 million Tax Year 2016 tax returns claiming the Excess Social Security Tax Credit. These taxpayers received credits totaling more than $3.1 billion. The Treasury Inspector General for Tax Administration (TIGTA) initiated an audit to follow up on TIGTA’s previous audit recommendations and to evaluate the IRS’s efforts to detect and prevent erroneous Excess Social Security Tax Credit claims. TIGTA’s analysis of more than 2.5 million tax returns e-filed in Processing Years 2017 and 2018 with an Excess Social Security Tax Credit claim found that processes implemented in response to TIGTA's prior audit have improved the IRS’s identification of questionable claims. However, the IRS paid more than $74 million in potentially erroneous Excess Social Security Tax Credits as a result of incomplete Social Security tax credit selection criteria, insufficient procedures, and tax examiner processing errors. In addition, incorrect return selection criteria resulted in the IRS unnecessarily expending approximately $1.1 million to manually review 737,735 valid Social Security Tax Credit claims filed during Processing Years 2017 and 2018. Finally, the majority of potentially erroneous Excess Social Security Tax Credit claims identified by its post-processing income matching program continue to not be addressed. To see the full report, go to www.treasury.gov/tigta/auditreports/2019reports/201940026fr.pdf.

In Levon Johnson (152 T.C. No. 6) the taxpayer received $4,460 in 2014 in monthly advance payments of the premium tax credit (PTC) under the Affordable Care Act. His reported modified adjusted gross income (MAGI) was within the amount needed to qualify him for the PTC. He did not include in his MAGI all Social Security benefits received during 2014, which included a lump sum attributable to 2013. In his amended 2014 Federal income tax return he made an Sec. 86(e) election to exclude a portion of the 2013 Social Security benefits received during 2014 from his gross income. His amended return showed $1,250 of excess advance payments of the PTC. The IRS determined that the taxpayer's excess PTC was the entire $4,460 because, under Sec. 36B, all of his Social Security benefits received during 2014 (including those relating to 2013) must be included in computing whether he was entitled to the PTC. The inclusion of all Social Security benefits would result in the taxpayer having MAGI outside of the range for entitlement to the PTC. The Tax Court held that for purposes of determining a taxpayer's eligibility for a PTC under Sec. 36B, MAGI includes all Social Security benefits received during the taxable year irrespective of any Sec. 86(e) election. The Court sustained the IRS's determination.

Tip of the Day

Self-employment income . . . The threshold for reporting income from a side business is zero. That is, you've got to report all income from a side business or full-time business that is just starting up. For example, Fred is a licensed plumber normally working only for a contractor who pays him a salary. However, last year he made $450 from two small jobs he did outside of his regular job. The $450 has to be reported as gross income on Schedule C. He bought $60 worth of parts. (Don't net any deductions against income before reporting the income.) He can deduct the parts expense on Schedule C, reducing his net earnings to $390. There is a break here. Because his net earnings from self-employment were no more than $400, he doesn't have to report the $390 ans self-employment income for FICA purposes (Schedule SE).

 

March 18, 2019

News

The threshold for the underpayment penalty is usually 90 percent. The IRS has already dropped that to 85 percent to ease the pain for the taxpayers who owe an unexpected amount of tax this year. Congress is urging even more relief and Treasury Secretary Mnuchin has indicated that the threshold could be dropped to 80 percent.

You have two options if you want to contest the IRS's action in court. Don't pay the tax and go to Tax Court or pay the tax and sue for a refund in district court or Federal Court of Claims. In Lawrence Danduran (U.S. District Court, D. North Dakota) the petitioner sought a refund of tax penalties for failure to pay over withheld taxes. The Court noted the petitioner was involved in the day-to-day operations of the partnership, was a 50-percent partner, and could hire and fire employees. The Court reasoned that qualified him as a responsible person and sustained the IRS penalties.

Tip of the Day

Required minimum distributions . . . You're required to take required minimum distributions from traditional IRAs after you reach age 70-1/2. In the year you reach age 70-1/2 you can take the distribution as late as April 1 of the following year. For example, if you reached age 70-1/2 September 15, 2018. You must take your first distribution by April 1 of this year. Subsequent distributions must be taken by December 31. Continuing the example, you must take your required distribution for 2019 by December 31 of this year. Keep in mind that the distribution must come from a traditional IRA account. Taking a distribution from a Roth doesn't count. If you have multiple traditional IRAs you can take all of your distribution out of one. That's not true for other plans. Required minimum distributions must be taken out of each plan. And special rules apply to individual retirement annuities.

 

March 15, 2019

News

The filing deadline for corporate and partnership tax returns (for companies on a calendar year) is March 15. Most states have the same deadline. You can file and extension, but, like for individual taxpayers, you must pay any liability no later than the due date.

The IRS has a correction program that permits any size business or organization that sponsors a retirement plan (including SEP and SIMPLE IRA plans) to identify and correct problems they find. This correction program, the Employee Plans Compliance Resolution System (EPCRS), is outlined in Revenue Procedure 2018-52. The Voluntary Correction Program (VCP) works for mistakes that are not eligible for self-correction or if you want IRS assurance about how you corrected a mistake. The IRS is reminding businesses that Beginning April 1, 2019, you must make all VCP submissions electronically through Pay.gov. Any paper VCP submissions sent to the IRS with a postmark after March 31, 2019, will be returned to the applicant. For more information, check out this IRS video and review Updated Retirement Plan Correction Procedures that discuss the VCP submission process.

As long as you mail your petition to the Tax Court on time, it's considered filed on time. In Teri Jordan (T.C. Memo. 2019-15) the Court dismissed the petition for lack of jurisdiction. The postmark dates (there were three--two by the USPS and one a private postmark) was some 90 days after the last date for filing.

Tip of the Day

Basis adjustments . . . The term basis is used to describe your "cost" in an asset. If you simply buy, hold, and sell securities, that's often what you paid for the stock. But sometimes it's not that simple. Reinvest the dividends through a dividend reinvestment plan? Those purchases increase your basis. Get a nondividend distribution? It's not taxable, but it reduces your basis in the stock. Sell stock or a mutual fund at a loss and repurchase shares within 30 days, the loss will be disallowed but can be added to the basis in the shares purchased. Stock acquired by inheritance has a basis equal to fair market value at the date of death of the decedent. Shares acquired from a spouse incident to a divorce has the same basis as in the hands of the original holding spouse. Shares acquired by gift take on the donor's basis--but some special rules apply. There are some other special situations. Best approach? Discuss the situation with your tax advisor.

 


Copyright 2019 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information is not necessarily a complete summary of all materials on the subject. Copyright is not claimed on material from U.S. Government sources.--ISSN 1089-1536

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