Carried Interest Tax Increase, S Corporation Curbs Softened in New Tax Extenders Proposal by Senate Finance Panel Chair Baucus

Senate Finance Committee Chairman Max Baucus (D-Mont.) June 16 introduced a new substitute amendment (S. Amdt. 4369) to the tax extenders bill (H.R. 4213) that would…

BNA INSIGHTS: Tax Liens: Treasury’s Uncertain Tax Position?

The Tax Court in a reviewed decision, Intermountain Insurance Service of Vail LLC v. Commissioner, rejected the Internal Revenue Service’s argument that a temporary regulation…

American Institute of Certified Public Accountants Offers Comments to Treasury, IRS on Foreign Bank Account Report Guidance

The American Institute of Certified Public Accountants May 17 unveiled comments on requirements for taxpayers required to file the Report of Foreign Bank Account (FBAR) …

IRS, Treasury Outline Intent to Issue Rules Stemming from ‘Subpart F Income Partnership Blocker’ Deal Transactions

Treasury and IRS indicate in Notice 2010-41 their intent to issue regulations to classify certain domestic partnerships as foreign for purposes of identifying the U.S. shareholders of a controlled foreign corporation that must include, in gross income…

Tax Court Says IRS’s Temporary Rules on Partnership Basis Overstatements Invalid

A majority of the U.S. Tax Court May 6 held invalid temporary regulations (T.D. 9466) issued by the Internal Revenue Service defining an overstatement of basis as an…

IRS Uncertain Positions Documents Answer Some Questions, Leave Others, Practitioners Say

The draft schedule and instructions that taxpayers would use to report uncertain tax positions, unveiled by the Internal Revenue Service April 19, are administratively helpful and well…

IRS Unveils Draft Schedule, Instructions for Reporting Uncertain Tax Positions

The Internal Revenue Service April 19 unveiled the eagerly awaited draft schedule and instructions that taxpayers would use to report their uncertain tax positions under…

Seventh Circuit Overturns Tax Court Ruling on Exempt Interest Expenses of Qualified Subchapter S Subsidiary Bank

The U.S. Court of Appeals for the Seventh Circuit March 17 found that shareholders in an S corporation—which is the sole shareholder of a tax code Section 1361(b)(3)(B) qualified…

Government Cannot Impose 40 Percent Penalty for Participation in Son of BOSS Tax Shelter, Texas Judge Rules

A magistrate judge for the U.S. District Court for the Eastern District of Texas March 9 found that the government cannot impose a 40 percent penalty for…

IRS Guidance on Series LLCs Expected to Be Issued Soon, Official Says

Guidance on series limited liability companies is expected to be out very soon and at least before…

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