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IRS Pays $175,000 in Damages for Willfully Violating Bankruptcy Discharge By Making Collection Attempts Upon Discharged Debtor
Category: Tax
In a battle of competing statutes, the First Circuit Court of Appeals has held that the IRS’s good faith belief that it had a right to collect debts discharged in bankruptcy because the debtor had filed a fraudulent return or willfully attempted to evade or defeat tax, was an insufficient basis to…
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IRS Says Not So Fast to States' Attempts to Convert High State and Local Tax Obligations to Charitable Deductions to Escape TCJA Limitations
Category: Tax
In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid the limitations on the deductibility of state and local taxes under the Tax…
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Impact to Charitable Organizations under the Tax Cuts and Jobs Act
Category: Tax
While many businesses and individuals will see a lower tax bill as a result of the 2017 Tax Cuts and Jobs Act, charitable organizations may ultimately be the biggest losers from the sweeping tax reform. The Tax Act includes several changes that eliminate the tax savings incentives for charitable…
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Impact of Tax Reform on the Kiddie Tax and Transfers to Minors
Category: Tax
By now, we all know that major tax legislation was passed in December of 2017. The 2017 revenue act (the “2017 Tax Act”) is officially titled “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” but it is more commonly…
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I Missed a Tax Election…Now What? Requesting 9100 Relief
Category: Tax
What do we, as tax professionals, do when we discover (or our clients discover) that a tax election has been inadvertently missed? There may be a solution for some missed elections. Regulations §§ 301.9100-1 through 301.9100-3 contain rules permitting extensions of time for certain late tax…
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