Category: IRS
Tax Court reminder – IRS levies on IRA accounts are taxable
The United States Tax Court recently issued a Memorandum opinion reminding taxpayers that when the Internal Revenue Service (IRS) seizes an Individual Retirement Account (IRA), the seized IRA needs to be included as taxable income. Lonnie Wayne Hubbard v. Commissioner of Internal Revenue (T.C. Memo. 2024-16). In 2017, disgraced…
IRS ISSUES CONSEQUENTIAL RULING ON TRUST MODIFICATIONS
Chief Counsel Advice (“CCA”) 202352018, an internal legal advice memo from the IRS National Office to field agents, released December 29, 2023, addressed the gift tax consequences to the beneficiaries of modifying an irrevocable trust that is a “grantor trust” under the tax code provisions of Internal Revenue Code (“I.R.C.”…
New Priority Guidance Plan Announced For Limited Partner Exception to SECA
NEW PRIORITY GUIDANCE PLAN ANNOUNCED FOR LIMITED PARTNER EXCEPTION TO SECA For a number of years there has been an ongoing challenge by the IRS of taxpayers claiming limited partner status and exemption from the Self-Employment Contributions Act (SECA) tax. The activity in this area has greatly increased in…
IRS Announces Withdrawal Process for Employee Retention Credit Claims
On October 19, 2023, the IRS announced the details of a special withdrawal process to help those who filed an Employee Retention Credit (ERC) claim and are concerned about its accuracy. The process has been announced as part of a larger effort to protect small businesses and organizations from scams,…