IRS Offers Settlement to Taxpayers Audited for Micro-Captive Insurance

Posted · Add Comment

The Internal Revenue Service announced in IRS Notice IR-2019-157 that it would send time-limited settlement offers to certain taxpayers who participated in abusive micro-captive insurance transactions and are under audit. Eligible taxpayers will be notified of this offer by a letter containing the applicable terms. The IRS has already sent notices to up to 200 […]

To Tax or Not to Tax…That is the Question

Posted · Add Comment

With the ups and downs of the financial markets over the last several weeks, it seems that political conversation has turned to the consideration of additional tax cuts as a vehicle for economic stimulus to ward off any recession that might be on the horizon. Recent discussions coming from the Trump administration have touted a […]

IRS Sets 2019 Vehicle Depreciation Limits  

Posted · Add Comment

The Internal Revenue Service has released the depreciation deduction limits for passenger autos (including trucks and vans) first placed in service during 2019. These annually inflation-adjusted numbers represent the maximum income tax depreciation allowed under the luxury automobile rules. In Revenue Procedure 2019-26, tables set forth the new depreciation limits. Table 1 provides the depreciation […]

New Proposal to Tax Unrealized Capital Gains

Posted · Add Comment

An occasionally-discussed income tax concept relating to capital gains is being revived by the top-ranking Democrat on the Senate Finance Committee, Oregon Senator Ron Wyden. Wyden is proposing that certain wealthy taxpayers ante up each year for the value growth in their investment accounts rather than waiting for those investment assets to be liquidated and/or […]

Joint Committee on Taxation Addresses the QBI Deduction

Posted · Add Comment

One of the most discussed provisions of the Tax Cuts and Jobs Act (TCJA), which was enacted in December 2017, is the addition of the Qualified Business Income (QBI) deduction available under new Internal Revenue Code §199A. This provision allows equity owners of qualifying pass-through entities to deduct up to 20% of the qualifying business […]

Substantiation Rules for Charitable Contributions Continue to Baffle

Posted · Add Comment

As April 15th (the annual D-Day for U.S. taxpayers) is rapidly approaching, confusion still exists as to how to properly substantiate a donation or charitable contribution to a qualifying tax-exempt organization. The lack of clarity relates mostly to a seemingly endless series of technical changes to the substantiation requirements by the Internal Revenue Service. Obtaining […]

State and Local Tax Refunds & the Tax Benefit Rule

Posted · Add Comment

In years prior to 2019, and the enactment of the Tax Cuts and Jobs Act (TCJA), taxpayers were accorded an “unlimited” federal income tax deduction for all state and local income taxes as well as real estate taxes, if they were able to itemize deductions. In those instances when the state and local income taxes […]

Analyzing the TCJA’s Impact on States

Posted · Add Comment

Not subject to as much media attention as federal income tax legislation, the state impacts resulting from the enactment of federal legislation always poses budgetary challenges for leadership in those jurisdictions. Oftentimes, federal income tax incentives, such as accelerated and bonus depreciation, can prove unduly costly for states whose income tax regimes are predicated upon […]

PA Adopts Economic Nexus Standard for Sales Tax Collection

Posted · Add Comment

Sales Tax Background Most states have historically looked to nexus as a condition relevant to their capability to levy sales taxes. For decades, states have been bound by the United States Supreme Court National Bella Hess and Quill decisions in defining the required nexus standard for levying taxes in those states. The most relevant determinant of nexus […]