Category Archives: IRS

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IRS Announces June 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading

IRS Announces May 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The May 2017 rates generally reflect a slight decrease from the April rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The … Continue Reading

IRS Temporarily Halts PLRs on Certain GST Tax Issues

On March 3, 2017, Melissa C. Liquerman, a branch chief for the IRS Office of Chief Counsel, announced at the Federal Bar Association Tax Law Conference that, due to “budget cuts and prolonged strain on agency resources,” the IRS is temporarily suspending the issuance of private letter rulings (PLRs) relating to certain generation-skipping transfer (GST) … Continue Reading

IRS Announces Slight Increase for April 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The April 2017 rates reflect a slight increase from the March rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR … Continue Reading

IRS Announces Slight Decrease for March 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The March 2017 rates reflect a slight decrease from February’s rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that may come with rate changes. The … Continue Reading

The Unwanted IRS Time Machine – Is Your Gift Tax Return Actually Done?

Taxpayers may assume that once a gift tax return is filed, they can sit back and avoid worrying about the IRS making adjustments once the general three-year statute of limitations has passed. But the IRS has a powerful “rewind-the-clock” tool that taxpayers may inadvertently trigger if they aren’t careful when preparing any filed gift tax … Continue Reading

AICPA Suggests Adequate Disclosure Reference for Section 2704 Proposed Regulations

The American Institute of Certified Public Accountants (AICPA) recently published recommendations for a disclosure statement to be included on a U.S. Gift (and Generation-Skipping Transfer) Tax Return (IRS Form 709) disclosing the transfer of an interest in a family partnership or family controlled entity made on the same date or after the issuance of the … Continue Reading

IRS Announces Increase for February 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The February 2017 rates reflect a slight increase over January’s rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated … Continue Reading

2017 Federal Tax Inflation Adjustments

Each year, the IRS makes inflation adjustments to numerous thresholds, exemptions, exclusions, and other amounts that affect various tax calculations under the Internal Revenue Code. For example, annual inflation adjustments apply to the standard deductions available to taxpayers for income tax purposes, the filing thresholds for each income tax bracket, the amount available for annual … Continue Reading

IRS Defines ‘Spouse,’ ‘Husband,’ ‘Wife,’ and ‘Marriage’ for Tax Purposes

The IRS recently issued final regulations, effective as of Sept. 2, 2016, providing gender-neutral definitions of “spouse,” “husband,” and “wife,” and clarifying the definition of “marriage” for federal income, transfer, and employment tax purposes. Under the new final regulation section 301.7701-18(c), a marriage (same-sex or opposite-sex) will be recognized for federal tax purposes if it is … Continue Reading

Estate Tax Exemption Nears $11 Million (For a Married Couple)

The estate (and gift) tax exemption amount (exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift or estate tax on the value of the gifted assets.  This amount is adjusted annually for inflation, meaning that even if you exhaust your exemption amount by making substantial … Continue Reading

Does Fraudulent Conduct by Someone Else Extend the Statute of Limitations Permitting the IRS to Pursue the Taxpayer?

A fraudulent tax return is bad news for a taxpayer. Normally, the IRS has a limited period of time (3 years) to audit a taxpayer’s return.  The existence (or allegation) of fraud, however, gives the IRS an unlimited amount of time to make an assessment of tax liability.  But more importantly, taxpayers may be surprised … Continue Reading

Bill to Bar Air Excise Tax on Aircraft Management Fees Clears House Ways and Means Committee

A bill that would exempt aircraft management fees from the federal air transportation excise tax is advancing in the House — good news for aircraft owners who use a leasing company structure to save on state sales tax when purchasing aircraft. The bill (H.R. 3608) clarifies that fees paid to an aircraft services company to … Continue Reading

When a Fiduciary is Personally Liable for Unpaid Taxes

Although many people name family and friends as trustees or personal representatives in their legacy plan, it’s probably safe to assume that the people being appointed don’t have an understanding of the high level of responsibility inherent in carrying out their fiduciary duties.  One of the greatest fiduciary responsibilities is payment of a trust’s or … Continue Reading

Thinking of Expatriating? You May Be Leaving More Behind Than You Expected

U.S. citizens and long-term permanent residents who are considering relinquishing their U.S. citizenship or long-term permanent residency in the U.S. have more than just the exit tax imposed under Code § 877A to consider – they must also consider the impact the expatriation will have on their U.S. family members and other intended U.S. beneficiaries.  … Continue Reading

21st Century Do-Gooding Is Now in Vogue With the IRS

The past few years have seen a marked push by younger-generation leaders in corporate America to adopt investment and marketplace strategies that emphasize combining social good with the pursuit of financial return.  The problem for some private foundations who may have wanted to participate in “socially responsible investments” (SRI) is that such investments could be … Continue Reading

IRS Says Aircraft Leasing Entity is Eligible for 1031 Tax Free Exchange Treatment Despite Leasing to Related Companies at No Profit

We previously wrote about how a recently passed Texas bill (S.B. 1396) will allow certain in-state aircraft purchases to qualify for a resale exemption from sales tax, with the tax instead applied to later leasing contract payments. Now, a new IRS Chief Counsel memo says that an aircraft leasing partnership that trades in an aircraft that … Continue Reading

Your Favorite College Sports Team Tickets May Soon Feel More Expensive

It is a common practice among many top-tier universities and colleges to “require” that alumni or other donors make a threshold donation in order to obtain access to a ticket lottery to sporting event tickets.  Currently, the tax code permits donors making these type of “donations” to deduct 80 percent of the contribution amount, a … Continue Reading

GT Alert: Excise Tax Refund Opportunity for Foreign Reinsurers for Retrocession Policies

Greenberg Traurig’s Tax Practice recently published an alert discussing the excise tax refund opportunities for foreign reinsurers for retrocession policies.  The IRS has decided to back off its position that the one percent excise tax is due on a policy of reinsurance where a foreign reinsurer reinsures a policy of reinsurance issued by another foreign reinsurer … Continue Reading

Overdue Taxes? You Could Lose Your Passport

Pursuant to a new law that Congress is expected to pass in early December, the State Department could soon have the power to rescind the passports of people who have “seriously delinquent” tax debt.  Taxpayers with over $50,000 of unpaid federal taxes who are not in the process of resolving their debts with the IRS … Continue Reading
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