Paul L. Caron
Dean
Pepperdine Caruso
School of Law
IRS News
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Tax Analysts: ABA Estate Tax Committee Sends Comments on Gift Disclosure to IRS
On December 28, Edward M. Manigault, Vice Chair of the ABA Estate and Gift Tax Committee, sent to the IRS Comments of Individual Members of the ABA, Section of Real Property, Probate and Trust Law, Estate and Gift Tax Committee Concerning Adequate Disclosure of Gifts Reg-106177-98 (also available on the Tax Analysts web site at…
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Treasury & IRS Issue Four Press Releases Today
Treasury Issues Guidance Relating to Special Foreign Tax Restrictions No Longer Applicable to Iraq and Libya: Press Release (JS-2168) Rev. Rul. 2005-3 Treasury and IRS Issue Guidance on New Automatic Rollovers from Qualified Retirement Plans: Press Release (JS-2170) Notice 2005-5 Treasury and IRS Finalize Comprehensive Rules for 401(k) Plans: Press Release (JS-2171) T.D. 9169…
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Tax Analysts: IRS Bounces 379 Organizations from List of Approved Charities
Prudent folks making large charitable gifts rely on an organization’s inclusion in Publication 78 as a qualified public charity eligible to receive tax-deductible contributions. To provide guidance amidst the frenzy of year-end charitable giving, the IRS has released Announcement 2004-103, 2004-52 I.R.B. 1036 (12/27/04) (also available on the Tax Analysts web site), which lists the…
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Treasury Names Carroll & Solomon to Fill Tax Policy Roles
The Treasury Department yesterday announced (JS-2166) that Deputy Assistant Secretary for Tax Analysis Robert Carroll and Deputy Assistant Secretary for Regulatory Affairs Eric Solomon will assume leadership roles for Treasury tax policy until a new Assistant Secretary for Tax Policy is named. Carroll will provide economic advice and analysis with regard to tax policy issues. …
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IRS Issues Regs on Student Exemption from Employment Tax
The Treasury Department and IRS yesterday issued final regulations on the exception from employment taxes for services provided by students when those services are performed for a school, college or university: Although wages paid to students for working for a school, college or university are subject to income tax, a special exception excludes the wages…
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IRS Releases Update to 2004-05 Priority Guidance Plan
The Treasury Department and IRS today released an update (12/21/04) to the 2004-05 Priority Guidance Plan (7/26/04), which includes 33 new projects to implement the American Jobs Creation Act.
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Treasury’s Top Tax Policy Official “Unexpectedly” Resigns
Gregory F. Jenner, the Treasury Department’s top tax policy official, "unexpectedly" resigned as of noon Saturday to return to private practice. Jenner, Acting Assistant Treasury Secretary for Tax Policy, was nominated in July to be the permanent replacement for Pamela F. Olson, who resigned in April and joined Skadden. A replacement for Jenner is expected…
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IRS Issues Optional Sales Tax Tables
The IRS has released Publication 600: Optional State Sales Tax Tables: New for 2004, you can elect to deduct state and local general sales taxes instead of state and local income taxes as an itemized deduction on Schedule A (Form 1040). You cannot deduct both. Generally, to figure your state and local general sales tax…
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IRS Amends Circular 230
The IRS today issued final regulations amending Circular 230: The revisions to Circular 230 provide standards of practice for written advice that reflect current best practices and are intended to restore and maintain public confidence in tax professionals. These revisions ensure that tax professionals do not provide inadequate advice, and increase transparency by requiring tax…
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U.S. & France Sign Tax Treaty Amendments Today
Treasury Deputy Secretary Samuel Bodman and Jean-David Levitte, French Ambassador to the United States, will hold a ceremony to sign protocols amending the U.S.-France Income Tax and Estate Tax Treaties today at 3:00 p.m. EST in the Treasury Department’s Media Room (Room 4121), 1500 Pennsylvania Avenue, NW. Update: Deputy Treasury Secretary Samuel Bodman’s Remarks at…
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IRS Attorney Directory by Code Section & Subject Matter
The monthly update of the 121-page directory of attorneys in the IRS Chief Counsel’s Office, arranged by Internal Revenue Code Section and Subject Matter, is available on the Tax Analysts’ web site.
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Doctors and the IRS
In my federal income tax course, I often joke about the rich doctors who are parties to some of the seminal cases in the field. The IRS yesterday released a Fact Sheet for Medical Professionals (FS-2004-15) indicating that a growing number of doctors have shifted from aggressive tax planning to criminal tax evasion: Roth &…
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IRS Attorney Directory by Code Section & Subject Matter
The monthly update of the 121-page directory of attorneys in the IRS Chief Counsel’s Office, arranged by Internal Revenue Code Section and Subject Matter, is available on the Tax Analysts’ web site.
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IRS Announces 2005 Mileage Rates
The IRS has released the 2005 optional standard mileage rates for computing the deductible costs of operating an automobile for business, charitable, and medical or moving expense purposes: 40.5 cents per mile for business miles 15 cents per mile for deductible medical or moving expenses 14.5 cents per mile for services to charities The…
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IRS: Charity Cannot Administer Payroll Deduction Plan for PAC
In Technical Advice Memorandum 200446033 (June 14, 2004), released last Thursday, the IRS ruled that a § 501(c)(3)’s administration of a payroll deduction plan through which employees can contribute to a § 527 industry political action committee constitutes impermissible participation or intervention in a political campaign. Update (from reader Steven Sholk): See also PLR 200151060…
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SOI Releases New Estate Tax Data Set
The IRS Statistics of Income Division has released new data from Estate Tax Returns Filed in 2003, which include gross estate by type of property, deductions, taxable estate, estate tax and tax credits, by size of gross estate.
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IRS Releases Filing Projections for 2004-2012
The IRS’s Statistics of Income Division today released Calendar Year Projections of Information and Withholding Documents for the United States and IRS Service Centers, 2004-2012: Office of Research staff within Research, Analysis and Statistics of Income organization provides calendar year projections of information and withholding documents on an annual basis to accommodate the most recent…
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DOJ Gets Court Order Freezing $500 Million of xélan, Inc. in Tax Fraud Investigation
The Department of Justice yesterday obtained a TRO from the federal district court in San Diego freezing over $500 million in investment accounts maintained by xélan, Inc. The DOJ allegese that over 3,500 San Diego area doctors and dentists participated in fraudulent tax avoidance schemes employing purported supplemental insurance products or improper charitable deductions. For…
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IRS Wins Award for Best Government Web Site
The IRS issued a press release (IR-2004-131) today announcing that it has won a Keynote Performance Award, a new awards program designed to recognize excellence in web site performance. Keynote honored the fastest and most reliable web sites in three categories: e-commerce, e-government, and online travel and hospitality. In e-government, the IRS won the performance…
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IRS Announcements on Tax Shelters and 2005 Pension Limitations
The IRS yesterday announced: • IRS Tightens Position on Abusive Tax Shelter Settlement Terms (IR-2004-128): Under the new guidelines, the IRS will not settle unless taxpayers concede 100% of the claimed losses or deductions, reduced by only the amount of transaction costs up to 10% of the claimed losses or deductions. Furthermore, taxpayers must concede…
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IRS: Taxes Paid to Iraq Now Eligible for Foreign Tax Credit
The Treasury Department and IRS announced today (in JS-2045 and Rev. Rul. 2004-103) that the special foreign tax credit restrictions of § 901(j) no longer apply to income and taxes attributable to Iraq: Today the Treasury Department issued Revenue Ruling 2004-103 to reflect the decision of the Department of State to remove Iraq from the…
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IRS Attorney Directory by Code Section & Subject Matter
The monthly update of the 120-page directory of attorneys in the IRS Chief Counsel’s Office, arranged by Internal Revenue Code Section and Subject Matter, is available on the Tax Analysts’ web site.
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One More Batch of 527 Disclosure Forms Before Election
The IRS on Friday, in IR-2004-126, reminded 527 Groups that they must file one more disclosure form (Form 8872) listing their contributions received and expenditures prior to the November 2 election. These forms will be available to the public on the IRS web site and on other sites like OpenSecrets.org. For prior TaxProf Blog coverage,…
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Tax Act Retroactively Reinstates $250 Teacher Deduction
The IRS on Friday issued IR-2004-124, reminding elementary and secondary school teachers, counselors, principals and teacher’s aides that the Working Families Tax Relief Act of 2004 retroactively reinstated the $250 educator expense deduction, which had expired at the end of last year, for expenses incurred anytime in 2004 (and applies to 2005 expenses as well).…
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Today is Tax Deadline Day
Today is the final day for those million-plus taxpayers (including Teresa Heinz Kerry, but not folks living in designated disaster areas) who received automatic 4-month extensions on April 15 and discretionary 2-month extensions on August 15 to file their 2003 tax returns. For further information, see IR-2004-121 and this article by Tom Herman in the…