NJ Reduces Sales and Use Tax on Boats and Vessels
On December 9, 2015, Governor Christie signed into law, as P.L. 2015, c. 170, Senate Bill 2784 which provides a partial exemption and maximum sales and use taximposition for sales and uses of boats and vessels. The new law also establishes 30-day grace period for use tax imposition on certain boats…
New Code Section 7345 Could Jeopardize Passports for Taxpayers with Significant Tax Debts
On December 4, 2015, President Obama signed into law the “Fixing America’s Surface Transportation Act” (officially labeled the “FAST Act”) – P.L. 114-94. The bill’s primary takeaway is a 5-year, $305 billion plan to modify and modernize American transportation systems. However, hidden within the bill is a new Internal Revenue Code section…
FATCA and the New Frontier in Offshore Reporting Enforcement
* This article originally appeared in the October 2015 issue of Practical Tax Strategies, published by Thomson Reuters. Checkpoint Contents, Federal Library, Federal Editorial Materials, WG&L Journals, Practical Tax Strategies/Taxation for Accountants (WG&L) Practical Tax Strategies, 2015, Volume 95, Number 04, October 2015, Articles, FATCA AND THE NEW FRONTIER IN OFFSHORE REPORTING ENFORCEMENT, Practical Tax Strategies, Oct 2015 FATCA…
Tax Provisions from Congress’s New Highway Funding Bill
On July 31, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, H.R. 3236, into law. The Act makes many important changes to the Internal Revenue Code. For example, it requires additional information be included on mortgage interest returns, modifies basis reporting and…
Tax Court Upholds IRS Allocation of NOL Among Members of Consolidated Group
Four members of Marvel Entertainment Consolidated Group had Cancellation of Indebtedness (“COD”) income totaling $171,000,000 under IRC Section 108. The Taxpayer took the separate entity approach in reducing the group’s net operating loss carryforward by the amount of COD income. The Taxpayer first allocated to the four members their share of the…
Tax Court Upholds Farmer’s Current Year Deduction for Packing Materials Used in Subsequent Year
Agro-Jal Farming Enterprises, Inc. is a family owned farming corporation that produces strawberries and vegetables (the “Taxpayer”). The Taxpayer deducted the amounts paid for the packing materials in the year they were purchased even though they were not used until the following year. The IRS claimed that the Taxpayer was…
Proposed Regulations Eliminate Need to File IRC Section 83(b) Election with Individual Income Tax Return
BACKGROUND Section 83(b) provides in general that if in connection with the performance of services property is transferred to the person performing the services, the excess of the fair market value of the property as of the first time the transferee’s rights in the property are transferable and not subject…
Draft of Revised Form 3115 Released
On July 15, 2015, the IRS released a draft of a revised Form 3115, Application for Change in Accounting Method. Form 3115 is used for accounting method changes including those made to comply with the Tangible Property Regulations (“TPRs”) and those made for depreciation adjustments resulting from Cost Segregation studies. Prior to…
ALERT: Form BE-10 Required for Clients with Foreign Rental Real Estate By June 30, 2015
In recent years, tax practitioners who have clients with foreign assets have been inundated with information regarding offshore filing requirements. The vast majority of information publicized focuses on the FBAR filing requirement, with supplementary focus on forms required to be filed with a taxpayer’s Form 1040 (such as Forms 8938…
The Cadillac Tax: The End of Employer-Sponsored Healthcare?
Signed into law on March 23, 2010, The Patient Protection and Affordable Care Act, more commonly referred to as the Affordable Care Act (ACA) or Obamacare, represents a major overhaul of the United States healthcare system. Leading up to the 2008 presidential election, then Senator Barack Obama promised to make…