Podcasts about revenue procedure

In this episode, Cary Sinnett is joined by renowned CPA and tax expert Bob Keebler to unpack the complexities of theft and casualty loss deductions under IRC Section 165. From pig butchering scams to IRA fraud and Ponzi schemes, this episode dives deep into the kinds of losses the IRS will—and won't—let you deduct, what qualifies as a profit motive, and how financial planners can guide their clients through one of the most emotionally and financially painful tax situations. Five Key Insights for CPA Financial Planners: Profit Motive Determines Deductibility To qualify under Section 165(c)(2), a theft or loss must stem from a transaction entered into for profit. Losses from romantic or emotional scams—where no profit motive exists—do not qualify. Five Scam Archetypes to Know A recent IRS CCA outlined five fraud scenarios: Compromised account scams Pig butchering (crypto fraud) Phishing and impersonation Romance scams Kidnapping/extortion schemes Only the first three had profit motives and were deductible. The IRA Trap: The Tax Hit Before the Scam If a client is duped into withdrawing funds from an IRA and then loses the money to a scam, they face a double blow—taxable income and no deductible loss. CPA advisors must flag this risk early. Documentation Is Critical for IRS Support To substantiate a theft loss, clients need: Bank records (e.g., wire transfers) Law enforcement reports A clear, detailed paper trail showing the loss and the attempt to recover funds Directing the IRS to the assigned FBI agent can strengthen the claim. Mitigation and Planning: Protecting Vulnerable Clients Encourage older or high-net-worth clients to follow a “1–2% rule” on risky investments. Foster opens dialogue with family members and advisors to prevent fraud and ensure support if it occurs. Access resources related to this podcast: Note: If you're using a podcast app that does not hyperlink to the resources, visit Libsyn (PFP) to access show notes with direct links. IRC Section 165 IRS CCA 2025-101015 (the ruling discussed) Revenue Procedure 2009-20 (Ponzi Scheme Safe Harbor) AICPA PFP Section Guiding your clients who are financial caregivers Scam Tracker Risk Report This episode is brought to you by the AICPA's Personal Financial Planning Section, the premier provider of information, tools, advocacy, and guidance for professionals who specialize in providing tax, estate, retirement, risk management and investment planning advice. Also, by the CPA/PFS credential program, which allows CPAs to demonstrate competence and confidence in providing these services to their clients. Visit us online to join our community, gain access to valuable member-only benefits or learn about our PFP certificate program. Subscribe to the PFP Podcast channel at Libsyn to find all the latest episodes or search “AICPA Personal Financial Planning” on your favorite podcast app.  

Crypto tax expert Amir Marmar of JFDI Accountants breaks down the complexities of cryptocurrency taxation and shares guidance on when tax professionals should handle crypto cases themselves versus partnering with specialists. He explains key concepts like wallet-level reporting requirements coming in 2025, the challenges of DeFi and staking transactions, and why traditional tax software may not be enough for complex crypto cases. This episode provides practical insights for tax professionals on evaluating crypto clients and understanding the latest IRS guidance, including Revenue Procedure 2024-28's move away from universal accounting methods.SponsorsPadgett -  Contact Padgett or Email Jeff Phillips(00:00) - Welcome to Federal Tax Updates (01:56) - Amir Marmar's Background and Expertise (03:04) - Crypto Accounting Challenges and Success Stories (07:49) - Crypto-Friendly Government Policies (14:06) - Understanding Crypto Wallets (23:36) - Blockchain Basics and Tax Implications (29:38) - Complexities in Crypto Taxation (37:19) - Understanding Lending Protocols and Tax Implications (39:24) - Exploring Staking and Its Tax Considerations (41:11) - Liquidity Pools and Market Making (43:01) - Challenges in Crypto Accounting (44:11) - IRS Guidance and Tax Positions (46:02) - The Role of Tax Professionals in Crypto (49:39) - Steps for Successful Crypto Tax Engagements (52:50) - Upcoming Changes in Crypto Tax Reporting (01:04:53) - Contacting JFDI for Crypto Tax Help Connect with Amirhttps://www.jfdiaccountants.com/https://www.linkedin.com/in/amir-marmar-20b76726Get NASBA Approved CPE or IRS Approved CELaunch the course on EarmarkCPE to get free CPE/CE for listening to this episode.Connect with the Roger and Annie on LinkedInhttps://www.linkedin.com/in/rogerharrispbs/https://www.linkedin.com/in/annie-schwab-852418261/ReviewLeave a review on Apple Podcasts or PodchaserSubscribeSubscribe to the Federal Tax Updates podcast in your favorite podcast app!This podcast is a production of the Earmark Media

This podcast conversation with digital asset specialist Kirk Phillips, CPA, CMA, CFE & CPB, Managing Director — Global Crypto Advisors, focuses on demystifying IRS Rev. Proc. 2024-28, which provides guidance on transitioning from universal basis tracking for holders of digital assets and a safe harbor deadline of Jan. 1, 2025, to determine how to allocate any unused basis in digital assets. Phillips shares recommendations for tax practitioners around communicating with clients and the need for careful planning and documentation to meet the safe harbor provisions. What you'll learn from this episode: Understand more about Rev. Proc. 2024-28 and what it means for holders of digital assets. Hear about the safe harbor provisions provided in the revenue procedure. Learn the importance of the Jan. 1, 2025, deadline for making a reasonable allocation of unused basis. Find out about the challenges of documenting and reconciling cost basis related to digital assets. How to communicate and prepare individuals and businesses for the upcoming changes related to reporting of digital asset transactions.  AICPA resources Digital assets and virtual currency tax guidance and resources — Sharpen your tax knowledge on digital asset and understand the tax complexities and strategies involved with virtual currency and cryptocurrency. AICPA advocacy resources AICPA makes recommendations for digital asset transactions regulations, March 7, 2024 Other resources Rev. Proc. 2024-28 — Guidance to allocate basis in digital assets to wallets or accounts as of January 1, 2025 Final Regulations 2024-07-09 — Gross proceeds and basis reporting by brokers and determination of amount realized and basis for digital asset transactions Transcript April Walker: Hello everyone, and welcome to the AICPA's Tax Section Odyssey podcast, where we offer thought leadership on all things tax facing the profession. I'm April Walker, a lead manager from the tax section, and I'm here today with Kirk Phillips. Kirk is a CPA and it has a lot of other designations behind his name. But he's also more importantly for today's discussion, a specialist in the world of digital assets and crypto. [He's] been in it for a long time. Our goal today, Kirk, is to demystify some of this latest guidance that we've gotten from the IRS. We're definitely not going to be able to demystify all of it in the time we're just going to spend today. But there are some important deadline related items, so we want to make sure we're covering those. Kirk is on the AICPA's Digital Asset Tax Task Force. And for the past few months, we've actually been meeting weekly, which is unusual for a task force. Because really we've been discussing one thing, Revenue Procedure 2024-28. What it actually said, what it meant. Just really delving into that, the details of all of that. That's going to be the topic of what we're going to talk about today. What that means for tax practitioners and holders of digital assets. Especially like I said, there are deadlines around this safe harbor. Kirk, to start off. Welcome. Let's talk about I mentioned the deadline and let's talk about the significance of that January 1, 2025 deadline for making that reasonable allocation of unused basis. That's what the Rev Proc says. Talk to us a little bit about what that means, what you're thinking about, what practitioners should be doing now to prepare for that date. Kirk Phillips: Sure. Thank you so much April for having me on the podcast. I love talking digital assets and crypto, whether it's tax-related or otherwise. I'm excited to help demystify this Rev Proc. One of the key things here is that and why this is so important is we both have a short timeline. Because we're already nearing the last quarter of the year 2024. It's also very challenging - it's a onetime exercise that we have to go through and on a short timeline. That's why this is critical and that's why we're here today to talk about that. One of the key things here is that prior to this Rev Proc that the taxpayers would do their accounting for the digital asset transactions, which would be their trading or their sales, and it could be other related transactions as well. But basically they would do all the accounting on a universal basis. The question is, what does universal basis mean? Universal basis means that whether you have one wallet or one exchange account or you've got 37 wallets and six exchange accounts or even something more crazy than that, you would for the most part, more than 99% of the time people would use specialized tax software because that's really the only way to get the job done. You would connect all those things and or import your transactions into the software and it would essentially co-mingle all those transactions. I like to say as if it was one wallet or as if it was a single exchange. But it's not simply for the tracking purposes, all the transactions are simply dumped together and you perform one set of accounting. That's what the universal [method] is. Now, you can no longer use universal. You have to do a wallet by wallet, account by account basis. Which means that if you, again using those same numbers I did in my example there. If you had 37 wallets, that means you essentially have to do 37 different sets of accounting for those. I think that without knowing even anything more about it, an accountant hearing that would say, "Wow," immediately that sounds like that could be challenging, that could be a lot more work, and so on. There could be issues around that. And all those things are true. Because of this short timeline between now and the end of 2024 and essentially we're talking here at the end of September, so we got one-quarter left to do this. The important thing here is if you have any channels to communicate with your clients, the first thing to do would be to communicate with them and let them know, "Hey, there's this Rev Proc 2024-28." Maybe, perhaps even provided a link if you want to, and or read that yourself in detail at least once. But there's a lot of other things that you can lean on in AICPA guidance, of course. But just to send that out, in other words, you don't have to know it in detail before communicating. You should start the process communicating right now to say, "Hey, there's a lot to unpack here. I'm just letting you know there's going to be more that's coming. Be on the lookout. We're going to do a series of blogs on this or whatever it is you do or a newsletter, segments, and things like that. I think that's probably the number one thing to start off with is start the communication now, because this is not a one-shot communication thing. This is a series of communications that you're going to need to do. Whether you're just providing value to non-clients or you're working with current clients, you're going to need them to be thinking in steps and increments along the way. April Walker: Yeah. That's a lot of what we've been talking about over the past couple of months. Who this actually applies to you and who needs to really take notice of this? I think that's a great suggestion. Our listeners might be thinking, "Hey, I didn't know that we are not allowed to use universal method of basis allocation anymore. Did that come from the revenue procedure or where did that come from?" Kirk Phillips: Well, that actually came from the digital asset broker regulations. But then what happened is in the process of those becoming final and the fact that universal [tracking] comes to an end. And we have to do the wallet by wallet approach. What arises from that is a onetime exercise of how do we get from one thing to the other thing? How do we get from point A to point B? April Walker: The Sec. 6045 regs, which are long and complicated. Again, like Kirk said, we'll continue to create resources around all of this information because it's a lot to unpack. In the revenue procedure, it talks about a safe harbor. As we're transitioning between universal and wallet by wallet, the procedure provides a safe harbor. Let's talk about what are the key criteria that qualify you for using that safe harbor and give some of the requirements for it and so talk a little bit about that. Kirk Phillips: Sure. That's one of the big things here is what are those key criteria for the safe harbor? Of course, another thing is we're wondering what is it actually a safe harbor from? There's going to be more to come on that. Because that's actually not super clear and usually that is when it comes to safe harbor. The critical things here are that you have two methods that you can follow in this universal transition process. From universal cost basis tracking. In that transition process you can use a specific units method or you can use a global allocation method. In either case, you need to do some work before the end of the year arrives at 12-31-24, or before January the 1st, whichever way you want to say that. Those two methods are two distinct ways of doing it. You might say that the global allocation method is more straightforward and less work or less complicated. But let's just unpack those briefly. There's more to dig into on these, but this is a brief touchpoint. Let's start with global allocation. Global allocation, I like to think of it as more like a recipe. There's more than one way to get the "cake baked". Because you've got your grandmother's recipe and you've got your own style and you've got things like that and things in the cookbook. So you can arrive at a different cake, but if you follow the recipe, you're going to get the same cake. Basically, another way I like to say it too, is if you come up with a global allocation, which is simply saying, "You know, what I want to do is I want to allocate my Ethereum, my ether. And I want to take some low-cost basis. Maybe you could say, "I want to use my oldest cost basis and I want to apply it to my oldest wallets." For Bitcoin, I had only two Bitcoin wallets and one of them, it's only collected Bitcoin, received Bitcoin, it hasn't sold any. Say, you want to allocate maybe what's already there. Whatever it is, you're really defining a process. You're not actually going through with the process, you're simply defining it. The key distinction about global allocation is, if you define the process and if you were to give it to, let's say another CPA, they will come up with the same answer. If you give it to CPA A, CPA B, or CPA C, they should all come up with the same answer. It's very systematic. That's the distinction there. Now with the specific units, it's simply user's choice. Like in baseball, it's a fielder's choice. It's user's choice. It's however you want to allocate it specifically. Again, you have to follow the date. You can't break the date in the basis or a specific lot based on the date that it was purchased. You can't break that up. At that level that's as granular as you can get. If there was a lot or a tranche of Bitcoin or whatever, AVAX, or just pick your favorite coin and that was purchased on a certain date. You can't break up the date because the date piece has to be maintained and be consistent. Anyway, that's really just a user's choice scenario. That's the difference because you can't give that method to three other CPAs and have them come with the same result because that's not what it is. It has nothing to do with following a process. It's simply just a user's choice. Now the key thing on the dates there is that the specific units method has to be conducted and finalize before the end of the year, before the last day of the year. With the global allocation method, you just need to come up with the formula for doing it by the end of the year. But you actually can apply the formula to get the allocation after that. That's a super important point right there. Under global allocation, you also have until either the original due date or even the extended due date of the tax return if you did not conduct a transaction. The key is not having any transactions. You've got to put a halt to your transactional activity until you apply the global allocation method. But it does buy you more time to do it. You just gotta be careful because that's how you could throw off the safe harbor. And ruin the safe harbor if you don't put a halt to the transactions before doing the allocation. April Walker: You mentioned in one of our discussions is about what is this a safe harbor from? Based on our best discussions and where we think we are now, what do you think about that? What is it a safe harbor? What is our alternative if we blow this safe harbor. Kirk Phillips: That's a great question. It looks like it would be a safe harbor prospectively from this day forward or the end of the year exercise that we're talking about forward. We're not sure about retroactively. It mentioned if you don't follow the safe harbor, you can incur penalties and interests. As I recall that's about as deep as it goes. You could draw an inference from that and say, if I don't follow the safe harbor, does that mean that all of my transactional activity, all my reporting for the prior years could be recast and recalculated under different cost basis method. And therefore end up with a different tax liability than you originally calculated. Those things can be worst-case scenario. We just don't really know. April Walker: Usually when you have a safe harbor, you have rules of what to do and how to document that you have met that safe harbor. Again, things we've struggled with. Seems like a simple question right? But I'm telling you a lot of smart people in the room, this is not a simple question.  Kirk, as we know it now, what types of documentation do we think will be good enough to substantiate that we have met that safe harbor as of 1/1/25. Kirk Phillips: That's right. You could actually take an action. You could perform your allocation, and you could do this all before the end of the year. The question is, how do you prove that you've done it before the end of the year? People have talked about, well, you could have files saved that because you can look and see what a file date is, the modification date of a file. But then you could also later open up the file, not even change anything but potentially open a file, change the modification date. If that was something that is being looked at, then that could be an issue there. This is really where it comes into use in your CPA skills to figure out what's a good way to document. We're already good at that. Even in the world of not knowing, you can come up with "well I think I should do this" to document. One of the things is if there's a way to send an email to yourself. Time stamping on emails is one way to do things like that. Just in the larger world of documentation. Like I said, everybody is relegated to using specialized crypto tax software. You might as well say everybody uses crypto tax software. Then the question is, which one do you use? Because they're all different. They all have issues and so on. But hopefully regardless of the software, it would allow you to export an end of the year holdings report or an inventory report. That's essentially what it is because the data is in the software and if that's going to be one of the key things is, can I get that report? Let's just assume that you do. The first thing you do is to export that report. That's going to be the basis and the starting point for doing an allocation. Let's fast forward just a second. Let's say you go through the allocation however long that happens and let's say you're done. For example you could say, let me attach that file now. Again, figuring out how do you document. You could attach that file in an email or you're copying [yourself] with your client and maybe there's other members in the firm as well. Maybe there's a specifically designated digital asset person who want to get copied. But nonetheless, that would create an email timestamp on it and that document is attached to it. That's one way that you can actually document that these things were done ahead of time. I guess if we want to dive into documentation further again, I was talking about that inventory being a starting point. Regardless of whether you use this global allocation that we spoke about or specific units allocation. You would need to take the starting point of the ending balances or the inventory and then you need to take your wallets. Then you need to then allocate the basis that's in the wallet. Because remember it's on a universal basis. Now you're trying to allocate it on a wallet by wallet. You then need to go through it, but it's difficult to describe it without seeing a visual. But basically you would allocate all of the inventory that starting to all of the current wallets that you have. Again it depends on what method you're using. But at the end of the day, what you're trying to achieve is you want to get a proof. We all love proofs, and this is one way to do it. What's the proof? The proof is the check total. It could be a check total per asset, for example that you've allocated all the Bitcoin, you've allocated all the ether, you've allocated all the Solana, the AVAX, the whatever. You've allocated everything so that the check totals on the top match the check totals on the allocation. That's how you know that you've done it and it is complete and correct. Is by doing the methodology that is like that. Because if you don't do that then there's really no way to know that it's complete. You got to have checked totals and arrive at the same numbers and then that's how you do it. Again it can be challenging because it's depends on what's the quality of the data that you're starting with. One of the big challenges is I think all the software has different types of issues, limitations, certain features some have that others don't have and things like that. The first thought might be from the accountant mindset oh, if I split this inventory report out it's accurate. But the thing is, it's most likely not accurate. There's going to be issues with it. You're actually starting with something that's not solid in the first place, which creates a whole other set of challenges. But we can't dig too far into that one right now. April Walker: I was just went back into my way back machine and I was doing proofs and doing double underlines and I was getting really excited. I think that's a great point. If you are using software for yourself or for your clients, you need to, just like with everything we would say, you're not printing it out and then just putting it in a file or somewhere and never looking at it again. You got to make sure that it's not garbage in, garbage out situation. Again, lots of potential steps in this seemingly simple, allocate your basis comment. Another thing we've talked about is the role of brokers. Because eventually in the years to come, I'm sure you're aware, there's going to be in a form 1099-DA. And there's going to be reporting of digital assets and then hopefully there's going to be at some point, [cost] basis on those forms. Again, happy little world the basis is going to be equal to what you think it is and everybody's happy. I think we know that it's going to be much more difficult than it sounds, but let's stay simple for the moment. Let's talk about how that revenue procedure 2024-28 impacts how a broker might communicate with your clients regarding interactions with brokers and how this might be a help eventually. Kirk Phillips: That's all a great question and it's interesting how just the broker side of things, what were the centralized digital assets exchange. Because that's what we're talking about. It's just the two ways of saying it. But just to be clear what we're talking about because we have decentralized exchanges. Then the other side of that is the brokers and the centralized exchanges. And so that creates a whole another set of unique things and considerations with the brokers. And how they're going to report basis because they're the ones that are required to do it right now. We don't have it on the self custody side. I guess the overarching thing is you could end up with perpetual mismatches. And when I say perpetual, they could go on forever - definition of the word. But it could go on for a very long time. Just to make a point there, you have a perpetual mismatch between what you have been tracking with your crypto tax software and what the broker actually has on file. If it was Coinbase, for example, Coinbase and the assets that are on Coinbase were actually purchased there. Coinbase is going to have a record in that scenario. Then your tax software may have under the universal method have already spent some of that basis. Because again, those transactions are treated as if it was all one big wallet. You've got a mismatch off the start, even if you do a proper allocation on your own side, you may not even know what the broker has. So the question is, how can you communicate with the broker and let them know? The centralized exchange services or these brokers, they can receive user provided basis, but they're not required to, but they may accept it. If you have some that accept it, that may be one path that you could try to match up what you have from your allocation and communicate that to the broker so it matches up. But again, that's not going to be perfect because not every centralized exchange is going to do that. Only some of them are. Even in cases where they do provide that as a courtesy to their customers, that's not a magic wand either. If there's other things that can happen there, we could get into the weeds further on that. But one of the things is when you transfer in tokens to a broker, that they don't have any cost basis there. Again, if you wanted to report it because they're accepting it, yes. Otherwise they wouldn't have the information. There's just no way for them to know. If you think about the different assets that they may have in your account, they're going to have some that they know the basis for which would be the ones that you traded with them. Then they're going to have other transferred in assets from customers and they're not going to have any basis information on that. That just exacerbates the issue of what basis they have, what information they have and what's getting reported. You're going to have basically you could have 1099-DAs and so on that get reported on your behalf or the basis information is not correct. I think you know what is going to happen in those cases. You can imagine the challenges of trying to reconcile. That's what it was going to come down to is creating a really challenging reconciliation process with what the broker reported and the software with the software not really having features enough to give you reconciliation, the ability to reconcile to the degree that we're talking about. April Walker: We've talked a little bit about there are times certainly where you get it 1099-B and the basis that the broker reports, doesn't match for this or that reason? It can be inherited and who knows a couple of different scenarios. But generally, you can rely on what the basis is. I'm not sure that's going to be the case in this situation. But again, we're just scratching the surface on some of these complex issues. More from an issue highlighting, you can recognize that this is coming. Kirk, This has been great, we've covered a lot of great information, gives us some good takeaways as we're wrapping up listening to this podcast and what can practitioners do in the next quarter coming up or then as they're starting working on a 2024 tax returns. Kirk Phillips: Yes, I've got some great key takeaways and key points here. Then again, these things will be some of the stuff that I was suggesting in the beginning where you incorporate it into your blogs and newsletters, etc. This ongoing communication that's going to be critical. One of those could be strategically setup and tee up this allocation process in such a way that it is less complicated and has less issues. There's really going to be a strategy that could alleviate some of that. It's not relegated to whatever challenging process is going to be for any specific client. One way you can do that as potentially consolidating wallets. If there's an example, like I said, the client that's got the 37 wallets and the six exchanges. You can consolidate those down. Now whether it whittles down to a single wallet, probably not, with that many for various different reasons. But if you could go from, say, 37 and six, what's that? Forty three. If you go from 43 and you're able to whittle that down to say four or five. You're automatically going to have less challenges and the less complicated allocation process. Really strategically consolidating assets and wallets is one way that could make this process easier. And then also similar and in conjunction with that could be to take the assets off the exchange. Because again, if you don't have the ability to communicate with that particular broker because they're not receiving user provided information. If you take the assets off the end of the year, and then you put it back, they're going to have a zero basis. Again, that's its own issue, but I think it's the lesser of the evils, if you will. It's a better scenario for them to have a zero basis because then you're going to report something for it. Rather than they have some number and you have some different numbers. It's kinda like cost basis cleansing and you could call it that. The other thing here is the third key takeaway. I talked about all crypto software has limitations and challenges and issues, all different from one another. You really need to know [whether the software can help]. For example, if a software provider is going to provide some tooling to be able to help in this process, they may actually provide it to the user. And say, hey, you could just click a box here and we're going to lock down the inventory. Then we're going to do this reallocation for you and you think to yourself, that's great. I don't have to do any of the work, but you're still going to need to check that. You can't just rely on that. Then furthermore, if there is anything [available] like that, the question [comes] back to safe harbor. Does just checking a box, is that an action that proves that I took an action, a timely action, and allows me to be in the safe harbor or not. I think one of the best takeaways is, regardless of any of these pathways, is that you got to have a workpaper of some sort. And it says, I examined this. Here's a work paper that shows I did the work. Because it's one of the things that the software doesn't lock down the previous inventory. Find out what software the person uses. Because you may know or you may not know. It depends how you work with the client. [You need to] really understand what is that software provider doing to handle this. That's another key thing. This is really a big, interesting brain teaser for CPAs who were in the digital asset space. April Walker: For sure and we appreciate you taking a walk with us down, at least to start or the path and more to come. Kirk, this first time you've been with me on this podcast. We call it Tax Section Odyssey. We think of it as an Odyssey, a journey toward a better profession. In doing that, I like to get a glimpse of my guests other journeys outside of the world of tax. What's something on your travel bucket list? Something you have planned. Give me something to add to my bucket list. Kirk Phillips: Yes. I will be going to Orlando in about a month to see my sister and I don't get to see her much. But one of the things I like to do is backpacking. I am involved with Scouts and I discovered backpacking in 2021 for the first time. I just love going on the Appalachian Trail and all different kinds of trails,  whether it's with Scouts or other things. That's one of the things I like to do a lot. April Walker: Nice being outside and in nature and there's some beautiful places to hike for sure. You'll have to share some pictures from your hike when you're back with us. Thanks again, Kirk. This was very informative for me, as it always is. I didn't give a shout out to our digital asset page, but I will certainly put it on the resources. Again this April Walker from the AICPA Tax Section. This community is your go-to source for technical guidance and resources designed especially for CPA tax practitioner like you in mind. This is a podcast from AICPA and CIMA together as the Association of International Certified Professional Accountants. You can find us wherever you listen to your podcasts and we encourage you to follow us so you don't miss an episode. If you already follow us, thank you so much and please feel free to share with a like-minded friend. You can also find us at aicpa-cima.com/tax and check out our other episodes, as well as getting access to resources mentioned during this episode. Thank you so much for listening. Keep your finger on the pulse of the dynamic and evolving tax landscape with insights from tax thought leaders in the AICPA Tax Section. The Tax Section Odyssey podcast includes a digest of tax developments, trending issues and practice management tips that you need to be aware of to elevate your professional development and your firm practices. This resource is part of the robust tax resource library available from the AICPA Tax Section. The Tax Section is your go-to home base for staying up to date on the latest tax developments and providing the edge you need for upskilling your professional development. If you're not already a member, consider joining this prestigious community of your tax peers. You'll get free CPE, access to rich technical content such as our Annual Tax Compliance Kit, a weekly member newsletter and a digital subscription to The Tax Adviser.

On this episode of the “GILTI Conscience” podcast, Skadden attorneys David Farhat, Nate Carden, Eman Cuyler and Stefane Victor, are joined by colleagues Fred Goldberg and De Lon Harris, both of whom have had distinguished careers with the IRS. Tune in to hear Fred and De Lon share their thoughts, insights and predictions on the latest IRS projects and initiatives, as they talk about what's going on at the agency, new funding, enforcement priorities and tips for a more successful interaction with the IRS.Want more? Check out this prior episode with Fred Goldberg as he shares insights from his 50 years in tax law.

IRS revises guidance on what is an SUV for the Clean Vehicle Credit and issues proposed Revenue Procedure for tips reporting.

In 2022, the Internal Revenue Service (IRS) released Revenue Procedure 2022 – 19 (Rev. Proc. 2022-19) to offer relief for businesses operating as S Corporations (S Corp) that have issues with their organizational documents. IRS guidance addresses six specific items that could potentially disqualify the status of an S Corp, with the most important of these items focused on a non-identical governing provision where distributions and liquidations are not always equal.Barry Weins, Tax Director, joins this episode of the Tax Beat podcast with Brooks Nelson, Partner and Strategic Tax Leader, and Sarah McGregor, Tax Director, to share more about Rev. Proc. 2022-19 and the benefits it brings to S Corps.Listen in as our team covers:2:22 – Background on S Corps4:43 – Maintenance of S Corp qualification5:50 – Common issues for S Corps dealing with IRS Relief9:53 – Background on Revenue Procedure13:16 – Key Points of Revenue Procedure14:33 – Compliance with Revenue Procedure 18:16 – Impacts on mergers and acquisitions involving S Corps19:59 – Issues S Corps should be thinking aboutRelated Resources:R&D Tax Credits: 2022 Year in ReviewTax Planning Opportunities For Executives with Incentive Stock Options StrategiesIRS Crackdown on Incomplete Transfer Pricing Documentation

This week we're discussing a Revenue Procedure that provides for a simplified accounting method change for research expenses.

Creating foreign entities to safeguard assets is not necessarily problematic for U.S. taxpayers, but failing to characterize them appropriately sure is. Taxpayers have utilized foreign vehicles called “stiftungs” for decades. Various court decisions and administrative rulings over the years have concluded that certain stiftungs should be treated as trusts. This triggers the duty for taxpayers to file several information returns with the IRS, the most critical of which are Forms 3520 and Forms 3520-A. Violations lead to large penalties, endless assessment periods, and other things taxpayers want to avoid. This article defines the concept of foreign trusts, chronicles the major cases and IRS rulings from 1955 to the present, explains the IRS's foreign trust compliance campaign, and explores potential relief for taxpayers thanks to a recent Revenue Procedure.

https://player.vimeo.com/video/658414387? https://www.currentfederaltaxdevelopments.com/podcasts/2021/12/19/2021-12-20-bbba-is-not-coming-soon   This week we look at: BBBA fails to clear Congress before adjourning for the year and Senator Manchin states he is a no vote on this bill Mileage rates released by the IRS IRS updates automatic changes for small business accounting methods added by TCJA IRS publishes, with minimal changes, annual disclosure Revenue Procedure

This week we look at: IRS rules taxpayers cannot deductions expenses that qualify for PPP loan forgiveness if reasonably expect forgiveness Revenue Procedure issued for taxpayer who don't get the entire expected forgiveness in the end IRS adds request for additional information on Schedules K-1 for Form 1120-S for 2020 IRS Commissioner indicates there will not any sort of broad relief for late filing and late payment of taxes No relief for late filing when CPA firm submitted efile return a few seconds late IRS updates ERC FAQ to deal with acquisition of employers who had taken out PPP loans Copyright 2020, Kaplan Financial Education

https://vimeo.com/471938009 https://www.currentfederaltaxdevelopments.com/podcasts/2020/10/25/2020-10-26-tax-basis-capital-accounts-and-the-2020-form-1065   This week we look at: Fees to enter a daily fantasy sports contest is a wager in the view of the IRS Taxpayers must follow all of the criteria listed in Revenue Procedure to take advantage of the ruling IRS adds retrieving funds from state unclaimed property fund to list of items for self-certification for late retirement plan rollover Withholding is required if an employer sponsored retirement plan transfers funds to state unclaimed property  fund Draft instructions for 2020 partnerships released outlining requirement to report K-1 capital accounts on tax basis CPA denied in attempt to reduce potential liability by claiming failure of another tax adviser in representing client to reduce penalty Short term extension granted to October 31 to file FBAR reports

This week we look at: Fees to enter a daily fantasy sports contest is a wager in the view of the IRS Taxpayers must follow all of the criteria listed in Revenue Procedure to take advantage of the ruling IRS adds retrieving funds from state unclaimed property fund to list of items for self-certification for late retirement plan rollover Withholding is required if an employer sponsored retirement plan transfers funds to state unclaimed property fund Draft instructions for 2020 partnerships released outlining requirement to report K-1 capital accounts on tax basis CPA denied in attempt to reduce potential liability by claiming failure of another tax adviser in representing client to reduce penalty Short term extension granted to October 31 to file FBAR reports Copyright 2020, Kaplan, Inc.

On this week's episode of BuzzHouse, Don Bernards and Garrick Gibson dissect the provisions on new legislation and regulations recently passed, including the differences between Notice 2020-23 and Revenue Procedure 2014-49. Providing a quick summary of the fourth relief package released at the end of April – roughly $484 billion – Gibson and Bernards detail where that money is being focused. And as new legislation is released, what could be included that would greatly impact the housing industry? Tune in to find out more.

In this week's Tax Credit Tuesday, Michael J. Novogradac CPA, shares updates on guidance from the Internal Revenue Service relating to the review and certification of Paycheck Protection Program loans. Then, he shares an exciting announcement about a Novogradac Opportunity Funds Listing milestone for funds raised. Next, he discusses Revenue Procedure 2020-21 and IRS Notice 2020-25 which give temporary guidance for the use of private activity bonds, and he discusses some affordable housing updates related to private activity bonds and the 4 percent low-income housing tax credit. He then talks about a letter sent to Treasury by nine Republican senators urging Treasury to provide relief for opportunity zones in the wake of COVID-19, and he discusses details of a letter sent by the Novogradac New Markets Tax Credit Working Group to Treasury and the CDFI Fund to issue guidance and postpone certain deadlines due to the pandemic. Next, he discusses IRS Revenue Procedure 2020-29 which temporarily allows taxpayers to electronically submit requests for private letter rulings and other requests for advice. Finally, he talks about changes proposed by the California Tax Credit Allocation Committee for allocating 2020 low-income housing tax credits.

In this week's Tax Credit Tuesday, Michael J. Novogradac CPA, shares updates on guidance from the Internal Revenue Service relating to the review and certification of Paycheck Protection Program loans. Then, he shares an exciting announcement about a Novogradac Opportunity Funds Listing milestone for funds raised. Next, he discusses Revenue Procedure 2020-21 and IRS Notice 2020-25 which give temporary guidance for the use of private activity bonds, and he discusses some affordable housing updates related to private activity bonds and the 4 percent low-income housing tax credit. He then talks about a letter sent to Treasury by nine Republican senators urging Treasury to provide relief for opportunity zones in the wake of COVID-19, and he discusses details of a letter sent by the Novogradac New Markets Tax Credit Working Group to Treasury and the CDFI Fund to issue guidance and postpone certain deadlines due to the pandemic. Next, he discusses IRS Revenue Procedure 2020-29 which temporarily allows taxpayers to electronically submit requests for private letter rulings and other requests for advice. Finally, he talks about changes proposed by the California Tax Credit Allocation Committee for allocating 2020 low-income housing tax credits.

This week we look at: SBA issues guidance on self-employed taxpayers and partners for PPP loan program Revenue Procedure issued explaining how to deal with retroactive change in life for qualified improvement property IRS gives guidance on filing Forms 1139 and 1045 via fax while Service Centers are shut down Proposed regulations released to set government portion of PTIN fee at $21 Procedures issued to deal with Forms 706 returned by private delivery services from closed Service Centers Copyright 2020, Kaplan, Inc.

Current Federal Tax Developments for the week of March 9, 2020: Sometimes Too Late Really is Too Late: IRS denies a taxpayer's request to make a late mark to market election under §475(f) Loss limits for passive activities, basis and at-risk also limit self-employment loss use Revenue Procedure grants relief for filing some information returns for certain foreign trusts Copyright 2020, Kaplan Financial Education

On February 19, 2020, the IRS issued two pieces of long-anticipated guidance on Section 45Q, Carbon Capture and Sequestration credits. In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit Beginning of Construction Guidance—Notice 2020-12 Partnership Allocation Guidance—Revenue Procedure 2020-12 Expected future guidance Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.

On February 19, 2020, the IRS issued two pieces of long-anticipated guidance on Section 45Q, Carbon Capture and Sequestration credits. In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit Beginning of Construction Guidance—Notice 2020-12 Partnership Allocation Guidance—Revenue Procedure 2020-12 Expected future guidance Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.

On February 19, 2020, the IRS issued two pieces of long-anticipated guidance on Section 45Q, Carbon Capture and Sequestration credits. In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit Beginning of Construction Guidance—Notice 2020-12 Partnership Allocation Guidance—Revenue Procedure 2020-12 Expected future guidance Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.

Guest David Kirk joins host Damien Martin to share his experience working at the Office of the Chief Counsel of the IRS. Listen to find out what it's like to be the principal author on a significant guidance project, observations on the first tax season under the Tax Cuts and Jobs Act (TCJA) and advice for a successful career in tax. TIME STAMPS OF WHAT'S COVERED How Dave Kirk came to work for the IRS [01:47] What it's like to work at Chief Counsel [04:50] Dave's experience working on the NIIT regulations [10:41] Unintended consequences in Rev. Proc. 2013-30 [12:40] Dave's approach to drafting a regulation [18:00] How accountants and lawyers approach regulations differently [21:29] Doing the best we can with the first tax season under the TCJA [25:46] Getting comfortable with uncertainty [31:51] Documentation is always important, and other best practices for extended returns [35:00] Lawyers are better writers than accountants [39:24] Dave's proudest achievement so far [44:57] Dave's favorite Internal Revenue Code Section (aside from 1411) [49:47] Closing thoughts on a successful career in tax [51:13] BIO FOR GUEST David Harrison Kirk is a partner within the private client services practice of EY's National Tax Department in Washington, DC. Throughout his career, Dave has focused primarily on the taxation of individuals, trusts, S corporations and partnerships and financial planning for high-net-worth family groups. Prior to joining EY, he was an attorney in the Passthroughs and Special Industries division of the Office of the Chief Counsel of the IRS. He was a principal author of the NIIT regulations under §1411 of the Internal Revenue Code and Revenue Procedure 2013-30, Uniform Late S Corporation Election Relief. Dave is the author of the Bloomberg-BNA Tax Management Portfolio on the §1411 tax. Connect with Dave on LinkedIn ADDITIONAL RESOURCES MENTIONED IN THE EPISODE Mentioned on the podcast: “An Interview with David Kirk: Beware the New Excess Business Loss Limitation” (Forbes) by Tony Nitti “Section 1411 – Net Investment Income Tax (Portfolio 873)” (Bloomberg) by David Kirk GET MORE “SIMPLY TAX” We're excited to also provide video content to strengthen your tax mind! Check it out on our new YouTube channel. A complete archive of our episodes is available on our website and YouTube playlist. We'd love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram | YouTube

Guest David Kirk joins host Damien Martin to share his experience working at the Office of the Chief Counsel of the IRS. Listen to find out what it’s like to be the principal author on a significant guidance project, observations on the first tax season under the Tax Cuts and Jobs Act (TCJA) and advice for a successful career in tax. TIME STAMPS OF WHAT’S COVERED How Dave Kirk came to work for the IRS [01:47] What it’s like to work at Chief Counsel [04:50] Dave’s experience working on the NIIT regulations [10:41] Unintended consequences in Rev. Proc. 2013-30 [12:40] Dave’s approach to drafting a regulation [18:00] How accountants and lawyers approach regulations differently [21:29] Doing the best we can with the first tax season under the TCJA [25:46] Getting comfortable with uncertainty [31:51] Documentation is always important, and other best practices for extended returns [35:00] Lawyers are better writers than accountants [39:24] Dave’s proudest achievement so far [44:57] Dave’s favorite Internal Revenue Code Section (aside from 1411) [49:47] Closing thoughts on a successful career in tax [51:13] BIO FOR GUEST David Harrison Kirk is a partner within the private client services practice of EY’s National Tax Department in Washington, DC. Throughout his career, Dave has focused primarily on the taxation of individuals, trusts, S corporations and partnerships and financial planning for high-net-worth family groups. Prior to joining EY, he was an attorney in the Passthroughs and Special Industries division of the Office of the Chief Counsel of the IRS. He was a principal author of the NIIT regulations under §1411 of the Internal Revenue Code and Revenue Procedure 2013-30, Uniform Late S Corporation Election Relief. Dave is the author of the Bloomberg-BNA Tax Management Portfolio on the §1411 tax. Connect with Dave on LinkedIn ADDITIONAL RESOURCES MENTIONED IN THE EPISODE Mentioned on the podcast: “An Interview with David Kirk: Beware the New Excess Business Loss Limitation” (Forbes) by Tony Nitti “Section 1411 – Net Investment Income Tax (Portfolio 873)” (Bloomberg) by David Kirk GET MORE “SIMPLY TAX” We’re excited to also provide video content to strengthen your tax mind! Check it out on our new YouTube channel. A complete archive of our episodes is available on our website and YouTube playlist. We’d love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram | YouTube

IRA Financial Group’s Adam Bergman discusses updates to the 60-Day Rollover Requirement Rules that have taken place with the new IRS Revenue Procedure 2016-47.

This week we look at: Reported IRS backlog of unanswered letters that arrived during the shutdown IRS publishes information on impact of shutdown on matters before the Tax Court W-2 wages Revenue Procedure made final at same time §199A final regulations come out More thoughts on the §199A final regulations Copyright 2019, Kaplan, Inc.

https://player.vimeo.com/video/313688639https://www.currentfederaltaxdevelopments.com/podcasts/2019/1/27/2019-01-28-irs-funding-restored-at-least-for-now Reported IRS backlog of unanswered letters that arrived during the shutdown IRS publishes information on impact of shutdown on matters before the Tax Court W-2 wages Revenue Procedure made final at same time §199A final regulations come out More thoughts on the §199A final regulations   Click to listen to the audio . Alternatively, you may download the file to your computer by right clicking your mouse, choosing "Save Target As", then selecting a location on your computer to save the file. Click to watch

The SALT Show Episode 39 (Update for Week of December 30, 2018) On this week's episode: • A review of the most important SALT developments in 2018 • A hodgepodge of issues from the last few weeks Link to SALT Podcast Survey Link to Revenue Procedure 2019-12 Links to share  the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay

The IRS released proposed regulations on the interest limit and changes in the foreign tax credit, along with an automatic accounting method change Revenue Procedure for revenue conformity.

https://player.vimeo.com/video/304011338https://www.currentfederaltaxdevelopments.com/podcasts/2018/12/2/2018-12-03-interest-regulations-are-out IRS releases the 163(j) interest deduction limitation proposed regulations Special real property election for infrastructure maintenance company Revenue Procedure released IRS memorandum describes what the IRS can question when an employer excludes meals from employee’s wages under §119 Foreign tax credit proposed regulations issued Automatic accounting method change procedures issued for §451(b) revenue conformity   Click to listen to the audio . Alternatively, you may download the file to your

Guest Nathan Clark joins host Damien Martin to review the recent recommendations made by the AICPA’s Tax Methods & Periods Technical Resource Panel on challenges associated with making accounting methods changes to adopt the favorable small business taxpayer provisions in the Tax Cuts and Jobs Act (TCJA). Nathan also reviews key takeaways from the recent guidance provided in Revenue Procedure 2018-40 TIME STAMPS OF WHAT’S COVERED [01:59] Overview of what changed under the TCJA [04:47] What’s an accounting method again? [06:10] The resource panel’s July 23 letter [07:51] Guidance under Revenue Procedure 2018-40 [12:01] Key takeaways from the guidance received [15:16] Section 481(a) explained [18:47] The opportunity to plan for lower tax rates under the TCJA [20:40] Section 263A uniform capitalization calculations [21:28] Changes in methods to account for inventories under the TCJA [25:09] Challenges in implementing the changes [32:48] Section 460 and accounting for long-term contracts [34:28] Need for clarification on the interest deduction limitation [36:16] Qualified Improvement Property [42:13] Other items in the July 23 letter [43:08] Training for marathons while keeping up with the pace of tax change BIO FOR GUEST Nathan is a tax partner in Dixon Hughes Goodman’s firm headquarters in Charlotte, North Carolina—SouthPark. He has a deep focus on accounting method changes and specializes in capitalization, depreciation and revenue recognition. Nathan has spoken for AICPA conferences, state CPA societies, and other continuing education events. He has published Tax Alerts and articles for AICPA’s The Tax Adviser, CCH’s Corporate Business Taxation Monthly, CFO.com, AccountingWEB and has been cited by CFO.com and CCH. Follow Nathan on Twitter Connect with Nathan on LinkedIn ADDITIONAL RESOURCES AICPA Tax Methods & Periods Technical Resource Panel AICPA Comments on Impact of Pub. L. No. 115-97 on Accounting Methods for Small Business Taxpayers Revenue Procedure 2018-40 Simply Tax Episode 21: TRPs After Tax Reform GET MORE SIMPLY TAX A complete archive of our episodes is available on our website and YouTube playlist. We’d love to hear from you! Email feedback and questions to SimplyTax@bkd.com Connect with Damien on social media! LinkedIn | Twitter | Instagram

Guest Nathan Clark joins host Damien Martin to review the recent recommendations made by the AICPA's Tax Methods & Periods Technical Resource Panel on challenges associated with making accounting methods changes to adopt the favorable small business taxpayer provisions in the Tax Cuts and Jobs Act (TCJA). Nathan also reviews key takeaways from the recent guidance provided in Revenue Procedure 2018-40 TIME STAMPS OF WHAT'S COVERED [01:59] Overview of what changed under the TCJA [04:47] What's an accounting method again? [06:10] The resource panel's July 23 letter [07:51] Guidance under Revenue Procedure 2018-40 [12:01] Key takeaways from the guidance received [15:16] Section 481(a) explained [18:47] The opportunity to plan for lower tax rates under the TCJA [20:40] Section 263A uniform capitalization calculations [21:28] Changes in methods to account for inventories under the TCJA [25:09] Challenges in implementing the changes [32:48] Section 460 and accounting for long-term contracts [34:28] Need for clarification on the interest deduction limitation [36:16] Qualified Improvement Property [42:13] Other items in the July 23 letter [43:08] Training for marathons while keeping up with the pace of tax change BIO FOR GUEST Nathan is a tax partner in Dixon Hughes Goodman's firm headquarters in Charlotte, North Carolina—SouthPark. He has a deep focus on accounting method changes and specializes in capitalization, depreciation and revenue recognition. Nathan has spoken for AICPA conferences, state CPA societies, and other continuing education events. He has published Tax Alerts and articles for AICPA's The Tax Adviser, CCH's Corporate Business Taxation Monthly, CFO.com, AccountingWEB and has been cited by CFO.com and CCH. Follow Nathan on Twitter Connect with Nathan on LinkedIn ADDITIONAL RESOURCES AICPA Tax Methods & Periods Technical Resource Panel AICPA Comments on Impact of Pub. L. No. 115-97 on Accounting Methods for Small Business Taxpayers Revenue Procedure 2018-40 Simply Tax Episode 21: TRPs After Tax Reform GET MORE SIMPLY TAX A complete archive of our episodes is available on our website and YouTube playlist. We'd love to hear from you! Email feedback and questions to SimplyTax@bkd.com Connect with Damien on social media! LinkedIn | Twitter | Instagram

Lynn Nichols Federal Tax Update Podcast Feb. 5, 2018, edition   Listen as Lynn Nichols provides commentary on 10 Items pertaining to current developments in U.S. tax law. This week’s topics include:   How the Tax Law puts pressure on Deemed Asset Acquisition rules. A combination of a 100% bonus depreciation with a 338(h)(10) election could result in the entire purchase price of a business being written off in the year of acquisition.   The Interest Expense Limitation is presenting challenges for partnerships. The TCJA limits the Interest Expense deduction; but there is one limitation at the partnership level and a second limitation at the individual partner level, and that can become troublesome.   When is a meal entertainment? Company picnics and holiday parties will still be deductible, but what is deductible in the way of entertainment expenses?   Revenue Procedure 2018-11, an annual update, on when proper preparation of a return will avoid accuracy-related penalties.   In an email from the Chief Counsel’s Office, the IRS advises when a full payment rule will apply to a Preparer Penalty. For example, when there’s a penalty for Failure to Produce Form 1099, you can pay penalty on one and litigate the issue, but that’s not possible when talking about the Preparer Penalty.   A statement by House Ways and Means Oversight Subcommittee chair Lynn Jenkins observes that taxpayers are losing faith in the dispute resolution process because the IRS is not providing opportunities face-to-face dispute resolution meetings.   The IRS leaves $21 million on the table in a contested refund case.   Carried Interest Holding Period: How is it to be treated, and at what point does it become a capital asset and lose its ordinary income?

Speaker: James A. Schmidt Description: The IRS has rules that apply to and define Tenant in Common ownership structures. Whether or not a TIC complies with these rules, and would not otherwise be deemed to be a partnership, can have significant consequences for real estate investments, especially those that seek to take advantage of Section 1031 exchanges. This program will cover the Revenue Procedure and some of the commentary that has been written about those rules. Materials available here: http://floridataxlawyers.org/wp-content/uploads/2015/03/James-Schmidt-Esq.-Outline-for-Tax-Considerations-for-Tenancy-in-Common....pdf  Nothing in this podcast is legal advice. Please seek counsel of your own choosing before making decisions that may impact you or your business. 

In this week's Tax Credit Tuesday Podcast, Michael J. Novogradac, CPA, begins with the general news section, where he talks about bonus depreciation guidance issued by the IRS last week through Revenue Procedure 2016-48. In the low-income housing tax credit section, he shares the recently released fiscal year 2017 fair market rents. Then, he talks about an important fair housing discrimination lawsuit that was dismissed last week, the Inclusive Communities Project Inc. vs. the Texas Department of Housing and Community Affairs. He also has news about how listeners can comment on HUD's fair housing Local Government Assessment tool. In new markets tax credit news, he talks about how one new community development entity in the Northern Mariana Islands has the potential to bring the new markets tax credit to the U.S. territory for the first time. In the historic tax credit section, he discusses a recent historic preservation milestone that Montana recently reached. And he closes out with renewable energy tax credit news, where he shares projections of solar tax credit redemptions in Iowa.'

In this week's Tax Credit Tuesday Podcast, Michael J. Novogradac, CPA, begins with the general news section, where he talks about bonus depreciation guidance issued by the IRS last week through Revenue Procedure 2016-48. In the low-income housing tax credit section, he shares the recently released fiscal year 2017 fair market rents. Then, he talks about an important fair housing discrimination lawsuit that was dismissed last week, the Inclusive Communities Project Inc. vs. the Texas Department of Housing and Community Affairs. He also has news about how listeners can comment on HUD's fair housing Local Government Assessment tool. In new markets tax credit news, he talks about how one new community development entity in the Northern Mariana Islands has the potential to bring the new markets tax credit to the U.S. territory for the first time. In the historic tax credit section, he discusses a recent historic preservation milestone that Montana recently reached. And he closes out with renewable energy tax credit news, where he shares projections of solar tax credit redemptions in Iowa. 

Click here to listen to IRA Financial Trust Podcast 17: IRS Revenue Procedure 2016-47 Rollover Requirement Updates August 26th, 2016 IRA Financial Trust's Adam Bergman discusses updates to the 60-Day Rollover Requirement Rules that have taken place with the new IRS Revenue Procedure 2016-47.

In this podcast, Bob Keebler covers Revenue Procedure 2014-18, which provides a simplified method for certain taxpayers to obtain an extension of time to make a portability election. Rev. Proc. 2014-18 provides an automatic extension for certain estates of decedents dying in 2011, 2012 and 2013 to elect portability. The extension applies to estates that would otherwise not have had a filing requirement, and allows the estates to file a return to elect portability until December 31. It includes the estates of same-sex decedents who were not eligible to elect portability until after the Windsor decision.

In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, discusses an update on the federal fiscal year 2014 and 2015 budgets and the looming debt ceiling. In low-income housing tax credit news, he alerts listeners to a 2014 audit from the Treasury Inspector General for Tax Administration Office of Inspections and Evaluations on the Tax Credit Assistance program (TCAP). In historic tax credit news, he informs listeners about an update to Revenue Procedure 2014-12, the safe harbor guidance for historic tax credit partnerships, and he shares state level news from Alabama and a summary of a recent U.S. Tax Court decision about the transfer of state historic tax credits between partners. In new markets tax credit news, he shares information about a bill that would extend the New Markets Tax Credit program and provide additional allocation for communities affected by the loss of manufacturing jobs and discusses the retirement of long-time new markets tax credit supporter Rep. Jim Gerlach.

In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, discusses an update on the federal fiscal year 2014 and 2015 budgets and the looming debt ceiling. In low-income housing tax credit news, he alerts listeners to a 2014 audit from the Treasury Inspector General for Tax Administration Office of Inspections and Evaluations on the Tax Credit Assistance program (TCAP). In historic tax credit news, he informs listeners about an update to Revenue Procedure 2014-12, the safe harbor guidance for historic tax credit partnerships, and he shares state level news from Alabama and a summary of a recent U.S. Tax Court decision about the transfer of state historic tax credits between partners. In new markets tax credit news, he shares information about a bill that would extend the New Markets Tax Credit program and provide additional allocation for communities affected by the loss of manufacturing jobs and discusses the retirement of long-time new markets tax credit supporter Rep. Jim Gerlach.

Notice 2011-66 provides guidance for executors of estates of decedents who died in 2010 regarding the time and manner of choosing to opt out of the estate tax have the carryover basis rules apply. Revenue Procedure 2011-41 provides safe harbor guidance regarding property acquired from estates of decedents who died in 2010. This audio stream provides an overview of the guidance and strategies to assist advisers and clients in making decisions.

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This episode is a re-release of the AICPA Tax Briefing for State Society Leaders conference call that took place January 12 - 13, 2009. Below, please find a summary of the major points covered in the call. FIN 48—There are two important FASB requirements for accounting for uncertain tax positions of non-public companies that your firm needs to do right now, and as the tax person in your firm or business, you’ll undoubtedly be involved. On October 15, 2008, FASB deferred the effective date of FIN 48 (Financial Interpretation No. 48, Accounting for Uncertainty in Income Taxes) for all non-public companies for one year, until 2009 for calendar-year companies. However, that means that in January of 2009, calendar-year private companies should complete a FIN 48 analysis of their year-beginning tax positions so that they can record the effect of the change in accounting method at the end of 2009. This analysis could be “backed into” later in the year, but as time passes it will be more difficult to recall all tax positions (not just those that are unlikely) for all types of taxes for all open years in all jurisdictions and what the level of certainty and values were under the law at the beginning of the year. So if a company has not already done this analysis and if it wants to report in accordance with GAAP, the earlier it starts now, the better. Another new FASB requirement relates to 2008 financials and any interim 2009 financial statements. A FASB Staff Position (FSP) was issued on December 30 that added reporting requirements for private companies that elect to defer the effective date for the adoption of FIN 48. Specifically, they must explicitly disclose that they are electing to defer the effective date and also disclose the company’s accounting policy for evaluating uncertain tax positions. This applies to 2008 financials and interim 2009 financials, until FIN 48 is adopted. The FSP doesn’t discuss specifics, but unless a company has something unusual, we hope that some standard language will suffice, such as “Management has elected to defer the application of FAS FIN 48, Accounting for Uncertain Tax Positions in accordance with FSP FIN 48-3. The Company will continue to follow FAS 5, Accounting for Contingencies, until it adopts FIN 48.” Additional information on FIN 48 for private companies is included in the February issue of The Tax Adviser magazine that most Tax Section members receive. Tax Practice Guides and Checklists—Tax section members receive an annual package of over 600 pages of engagement letters, organizers, checklists, and other practice guides, and they’re now posted online . These include return-specific checklists for preparing and reviewing tax returns. Some forms checklists come in simple and complex versions so that, for instance, you don’t have to use a complex individual return checklist for a child’s return. These practice guides are carefully prepared and reviewed by fellow practitioners for your use. They are up-to-date through the Emergency Economic Stabilization Act of 2008, and subsequent developments will be reported in your Tax Section E-Alerts. In prior years, we sent a CD-ROM version of the checklists, but to avoid delays in scribing and mailing the CDs and with most members now having broadband internet, this year we’re only distributing the checklists. You’ll have to log on and be recognized as a tax section member to access this premium web content, and if you’re not a member, you can join online at aicpa.org/tax or on the phone at 800/513-3037. Each document may be downloaded to your computer directly allowing you to use any or all of the Practice Guides and checklists at your convenience and without requiring you to be logged on to the AICPA web site. A “one click” option allows you to download the entire package in a few moments directly to your computer. Audio E-Alerts—Tax Section member receive bi-weekly emailed e-alerts that report current developments in tax law and practice. This emailed alert is necessarily brief and to the point, and we’re beginning expanded version in bi-weekly audio e-alerts that can be uploaded to your MP3 player or listened to online. Each alert will be approximately 15-20 minutes in length and can be accessed online. These audio alerts are available to AICPA members without charge, but they do not contain the links to the source documents that are included in the emailed version that goes to Tax Section members. These audio alerts may be of particular interest to younger staff and will help them become more knowledgeable about current tax developments. SSTS Exposure Draft—The AICPA Tax Division recently issued an Exposure Draft of revisions to the Statements on Standards for Tax Services (SSTSs). The draft addresses changes in federal and state tax laws affecting the provisions in SSTS No. 1, Tax Return Positions, and No. 8, Form and Content of Advice to Taxpayers, and also members’ requests for clarification. Corresponding revisions to the current SSTS Interpretations will be made at a later date. Revisions to SSTS No. 1 are proposed to clarify the need to satisfy both the AICPA standards and the standards of the applicable taxing authority. Revisions to SSTS No. 8 are proposed to address new requirements that apply when providing certain types of tax advice. In addition, the original SSTS Nos. 6 and 7 have been combined into the revised SSTS No. 6. The original SSTS No. 8 has been renumbered SSTS No. 7. Various revisions also have been made to the language of the original SSTSs. AICPA members are welcome to comment on the exposure draft, with comments due by May 15, 2009. Please send your comments to sstscomments@aicpa.org or to SSTS Comments, AICPA, 1455 Pennsylvania Avenue NW, Washington, DC 20004-1081. Section 6694 Penalties—The Emergency Economic Stabilization Act of 2008 lowered the reporting standard under section 6694 to “substantial authority” from “more likely than not” for undisclosed, non-tax shelter positions. This is the same standard that applies to taxpayers. The change is retroactive to the date when the higher standard was enacted, May 25, 2007. This is a great victory for CPAs that the AICPA had been fighting for since Congress raised the standard for preparers to a level higher than for taxpayers, creating potential conflicts of interest between CPAs and their clients. Section 7216 Final Regs—IRS regulations on the unauthorized disclosure of tax return information went into effect on January 1. Absent a specific, exception, Treas. Reg. section 301.7216 generally prohibits the disclosure or use of tax return information without the client’s explicit, written consent. Under section 7216, a tax return preparer is subject to a criminal penalty for “knowingly or recklessly” disclosing or using tax return information. Each violation of section 7216 could result in a fine of up to $1,000 or one year imprisonment, or both. AICPA members who are engaged in tax return preparation and tax planning services need to become familiar with Treas. Reg. section 301.7216 and Revenue Procedure 2008-35, the authoritative guidance with respect to a preparer’s disclosure or use of tax return information. In a practice guide for members, the Tax Section is providing several examples of consent forms which have been developed by CPA members for their discussions or consultations with individual clients. 1099B Forms Coming Two Weeks Later—The Emergency Economic Stabilization Act of 2008 extended the date by which brokers must furnish information forms to customers. This includes stock broker 1099-B forms and also other forms from brokers, including realtors. Beginning with statements furnished in 2009, brokers will avoid penalties if they furnish these forms on or before February 15 – as opposed to the old due date of January 31. This could further compress the return preparation season for practitioners. Form 1065 Extended Due Date—Last year, the Tax Division held discussions with IRS concerning the dilemma of the late receipt of Forms 1065, Schedule K-1 that has perplexed the clients of CPAs who prepare the Form 1040, 1065, 1120 and 1120S tax returns which include such K-1 information. On January 24, 2008, we recommended, as a short-term solution, that the Service open a regulation project to: (1) address the difficulties taxpayers face when receiving delayed Schedules K-1 and (2) move the extended due date for partnership returns from October 15 to September 15, thus providing a maximum extension of five months. On July 1, 2008, the IRS released proposed regulations which would, in fact, limit certain flow-through entities to a maximum 5-month extension. The Service has indicated that the proposed regulations won’t be finalized until they have had an opportunity to analyze any comments submitted. On September 24, 2008, the Tax Division submitted comments with regard to the impact on trusts. The AICPA generally supports limiting the extension of the due date for partnership returns to five months. However, our prior letter and comments did not consider the issue of the proper extended due date for fiduciary returns because we were primarily focusing on the filing problems created for individuals who are partners in partnerships. We believe that the extension period for fiduciary returns (i.e., Form 1041 for trusts and estates) should remain at six months, rather than being reduced to five months as set forth in the temporary regulations applicable to all returns which are due after January 1, 2009. The Division will be testifying at the IRS hearing on the proposed regulations on January 13, 2009. In addition, the Division is also considering suggesting possible legislative changes in this area taking into account our members’ attitudes as solicited in a survey earlier this year. Also, on October 29, 2008 representatives of the Partnership TRP met with the Joint Committee on Taxation a possible change to due dates and/or extended due dates of Forms 1065, 1040, 1120S and 1041 to relieve workload compression and to better manage the workflow of these returns. State Taxation of Nonresidents—The ACIPA has been closely monitoring a Congressional initiative that would affect the ability of states to tax nonresidents temporarily working within their jurisdiction. Currently the states that have an individual income tax have a wide variety of tipping points. Some do not impose taxes on nonresidents until they have worked as many as 30 days within the state; others seem to require only a day or two. This has resulted in much confusion and probably significant non compliance for businesses, such as many accounting firms that frequently have employees working in states where the employer does not have an office. A bi-partisan bill was introduced in the last congress that would have required all states to conform to a 60-day rule such that the non resident employee would not be subject to tax within the state until the employee completed more than 60 days of service within the state in a calendar year. Included in the bill was what we refer to as the “snap back” rule whereby, once the 60 days was exceed, the employer was responsible for withholding the non resident state taxes for all the days worked with the state, including the first 60 days. In response to pressure from state taxing authorities, in the final days of the 110th Congress the 60 day rule was lowered to 30 days while still preserving the Snap back” provision. We believe there is a strong possibility that the 111th Congress take up where they left off last session and pass the 30 day with snap back version. Although we would have preferred the 60 day rule or even the 30 day rule without the snap back, this measure would add a much needed level of certainty in the area of state taxation of non residents. Pension Legislation Changes—At the end of the year, Congress passed the “Worker, Retiree and Employer Recovery Act of 2008)” which liberalized the funding rules for single and multi-employer qualified retirement plans and the minimum required distribution rules (MRDs) for retirees who have reached age 70 ½. The bill also makes technical corrections to the “Pension Protection Act of 2006” (PPA ’06) Specifically, the bill would • Allow pension plans to smooth out unexpected asset losses over two years; • Provide a transition to the new funding rules; • Allow multiemployer plans to freeze their status based on the previous year’s funding level; • Allow pension plans that are less than 60 percent funded at the beginning of 2009 to look back to the previous plan year to ascertain their funding status; and • Suspend mandatory withdrawals from retirement plans or IRAs for individuals age 70 ½ or older during 2009. The Treasury Department and IRS plan to issue MRD relief for 2008 very soon. The changes were needed because of the confluence of PPA ’06 mandated minimum contribution increases with the current economic crisis. We are also considering advocating additional changes; we will survey members in business and industry to try to determine if they anticipate continuing funding difficulties. Obama Tax Agenda Although this is necessarily speculative, we tried to pull together some of the common denominators of what President Obama spoke about in his campaign and his economic advisors have been saying since the election. Following are our predications at this moment: • Estate tax – freeze 2009 – i.e. $3.5 mil exclusion and 45% marginal rate. AICPA is fighting for: o “portability” loosely defined as permitting a surviving spouse to “inherit” whatever portion of the exclusion was not consumed by the deceased spouse o “conformity” so that the same exclusion would apply for purposes of the gift tax and the generation skipping transfer tax • Marginal rates for individuals – no increase in 2009 and perhaps not for 2010 unless there is a significant recovery in the economy before then. o Some reduction in payroll taxes for lower and middle income individuals to be effective in 2009 as a stimulus to the economy o Once the economy has “sufficiently” recovered we are expecting the Administration to proposed increasing the rates on upper income individuals to those in place before the reductions of 2001 raising the top rate back to 39.6% • We expect a proposal to increase the rates for qualified dividends and long term capital gains to 20%. But this, too, may not be proposed until it appears we’re on the way to an economic recovery. • Individuals with IRAs may be able to avoid penalties if they withdraw, before age 59 ½ , some level of funds ($10,000 has been talked about) to tie them over the economic slump. • For businesses, the new president has supported a continuation of the bonus deprecation rules and the ability to currently expense as much as $250,000 of asset purchased and placed in service in 2009

Listen to our New Podcast on - 5 common questions pertaining to 1031 Tenant In Common (TIC) investments 5 common questions pertaining to 1031 Tenant In Common (TIC) investments: I heard partnerships do not qualify as “like kind” property for a 1031 exchange. How does the purchase of a Tenant In Common (TIC) interest differ from a partnership? The most profound reason is a 2002 IRS Revenue Procedure ruling. This ruling, Revenue Procedure 2002 dash 22, essentially set forth the guidelines whereby a TIC would be recognized as real estate, not as partnership. Hence, it could be used in a 1031 tax-deferred exchange. There was a small group of companies, mostly in southern California, offering TIC properties in the 1990’s as passive investment options for their clients. However, since the landmark ruling in 2002, TIC offerings have grown into a multi-billion dollar industry. How is a Tenant In Common (TIC) property structured? A Tenant In Common (TIC) investment represents co-ownership of real estate by two or more investors and is a form of holding title to real property. TICs permit up to 35 small to midsize investors to own an undivided fractional interest in a large, potentially institutional quality property/properties. TIC investors are on deed and considered a direct owner of the underlying real estate. TIC owners share “pro rata” in the potential income, tax benefits and capital appreciation of the property. Since the Internal Revenue Service issued guidance in 2002 (Rev. Proc. 2002 dash 22), TICs have become the preferred investment vehicle for real property investors who desire to defer capital gains taxes via a 1031 exchange and own property without the day to day management headaches. Who is a Tenant In Common (TIC) “Sponsor” and what role do they play? The TIC sponsor is a real estate firm who usually negotiates the purchase of the property, arranges the financing and distributes the potential income to the TIC investors. There are several key elements to consider before you choose which sponsor to turn your money over to for your 1031 exchange replacement property. The experience of the sponsor is extremely important. Typically, a sponsor with a solid track record and several years of experience can give an investor greater confidence than a new sponsor just now trying to tap into this growing, competitive market. An investor should also examine the experience of the key personnel of the company to determine how effective these individuals have been in acquiring, managing and eventually selling institutional quality properties in various real estate climates. For a sponsor to be most effective, they must demonstrate that they are committed to the longevity of the investors they serve. Can I contact my realtor to purchase a Tenant In Common (TIC) investment? Since 2002, when the IRS issued official guidance in Revenue Procedure 2002-22 on how Tenant In Common (TIC) investments would qualify for replacement property under Section 1031, the TIC industry has exploded into a multi-billion dollar a year business. However, since 2002, the vast majority of TIC investments have been sold through the securities industry by licensed securities representatives and broker-dealers, not through the traditional means of licensed real estate professionals. There is pending legislation with the National Association of Realtors and the SEC which would permit realtors to get involved. Can I do a 1031 exchange into more than one Tenant In Common (TIC) property? Yes. Depending on the equity amount and other factors of your individual exchange, you may have the ability to exchange into multiple TIC properties. This can potentially allow you diversify your investments by asset type and geographic location. For example if you sold a property for $1.5 million you could potentially acquire an apartment building in North Carolina, an office building in Texas and a shopping center in California. Subscribe to our iTunes 1031 Exchange Podcast

The IRS has issued a safe harbor treatment for §1031 exchanges involving property that previously had or subsequently has personal use.  Revenue Procedure 2008-16 outlines the tests taxpayers can meet to be given safe harbor status on the question of the properties being held for investment or business use to qualify for §1031 status.The materials for the podcast can be found at http://www.edzollars.com/2008-03-02_1031_Exchange.pdf .The podcast is sponsored by http://www.leimbergservices.com .

This PodCast is about Section 1031 exchanges of personal use property. The IRS has issued a safe harbor treatment for "1031 exchanges involving property that previously had or subsequently has personal use. Revenue Procedure 2008-16 outlines the tests taxpayers can meet to be given safe harbor status on the question of the properties being held for investment or business use to qualify for "1031 status.The materials for the podcast can be found at http://www.edzollars.com/2008-03-02_1031_Exchange.pdf This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This week we look at Revenue Procedure 2008-12 and final regulations under §7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers.  The new regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms.  These new requirements will take effect on January 1, 2009.The written materials for the podcast can be downloaded from http://www.edzollars.com/2008-01-21_Consents.pdf .The podcast is sponsored by Leimberg Information Services at http://www.leimbergservices.com .

This PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009.The written materials for the podcast can be downloaded from http://www.edzollars.com/2008-01-21_Consents.pdf . . Direct download: 2008-01-21.mp3 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009.The written materials for the podcast can be downloaded from http://www.edzollars.com/2008-01-21_Consents.pdf . . Direct download: 2008-01-21.mp3 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009.The written materials for the podcast can be downloaded from http://www.edzollars.com/2008-01-21_Consents.pdf . . Direct download: 2008-01-21.mp3 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009.The written materials for the podcast can be downloaded from http://www.edzollars.com/2008-01-21_Consents.pdf . . Direct download: 2008-01-21.mp3 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

The mark to market election under Section 475(f) can have a major impact for individuals that were unsuccessful in their attempt to become a day trader-which turns out to be the majority of those who try.  However, the election has rather strict requirements on when the election must be filed, and as the taxpayer in Knish v. Commissioner, TC Memo 2006-268, learned as he tried to unsuccessfully argue for the validity of his election filed 18 months after the date that Revenue Procedure 99-17 required it have been filed.The materials for this podcast can be downloaded at http://edzollars.com/2006-12-31_Mark_to_Market.pdf .The podcast is sponsored by Leimberg Information Services, found on the web at http://www.leimbergservices.com .

This PodCast is about the Section 475(f) mark-to-market election. The mark to market election under Section 475(f) can have a major impact for individuals that were unsuccessful in their attempt to become a day trader (which turns out to be the majority of those who try). However, the election has rather strict requirements on when the election must be filed - as the taxpayer in Knish v. Commissioner, TC Memo 2006-268, learned as he tried to unsuccessfully argue for the validity of his election - filed 18 months after the date that Revenue Procedure 99-17 required it have been filed.The materials for this podcast can be downloaded at http://edzollars.com/2006-12-31_Mark_to_Market.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This week we look at adequate disclosure under Revenue Procedure 2005-75 for purposes of escaping the substantial understatement penalty under Section 6662(a). Download the materials for the podcast from http://www.edzollars.com/Adequate_Diclosure.pdf. The podcast is being sponsored by Leimberg Services.

This week we look at adequate disclosure under Revenue Procedure 2005-75 for purposes of escaping the substantial understatement penalty under Section 6662(a). Download the materials for the podcast from http://www.edzollars.com/Adequate_Disclosure.pdf. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This week we look at adequate disclosure under Revenue Procedure 2005-75 for purposes of escaping the substantial understatement penalty under Section 6662(a). Download the materials for the podcast from http://www.edzollars.com/Adequate_Disclosure.pdf. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com