Every U.S. Tax Court opinion in an IRC section 482 case dutifully recites some variation of the necessary incantation: The IRS has broad discretion in applying section 482, and its determinations must be upheld unless the taxpayer can establish that the IRS abused its discretion by making adjustments that are “arbitrary, capricious, or unreasonable.” However,
Taxes
ABLE (Achieving Better Life Experience) accounts have been around since 2014, but if you are today years old when you are learning about them don’t be embarrassed. In ancient times, I had ten or so up and coming accountants whose careers I felt responsible for. I counseled them that clients expected them to have general
Today’s Social Security column addresses questions about what effects early Social Security spousal benefits can have in various benefit rates, how delayed retirement credits are applied and how a public pension can affect survivor’s benefit? Larry Kotlikoff is a Professor of Economics at Boston University and the founder and president of Economic Security Planning, Inc.
Time weighted rate of return and IRR (internal rate of return) are identical where there have not been any contributions or distributions from a portfolio during the measurement period. Differences between time weighted rate of return and IRR (also known as “money weighted rate of return” and “dollar weighted rate of return”) arise when there
Should death be taxing? Amid budget surpluses, states started slashing income taxes last year. But only two have made significant changes to their estate or inheritance taxes so far. Last year Iowa legislators decided to phase out the state’s inheritance tax by January 1, 2025. And this year Nebraska legislators made pro-taxpayer tweaks to its
Forbes compared more than 800 locales in America on everything from housing costs and taxes to healthcare, air quality, crime and climate change and natural hazard risk. These are the top 25 cities for retirees. After 30 years in Orange County, Calif., Rex and Barbara Scott picked up last year and moved to Sioux Falls,
President Joe Biden and Senate Finance Committee Chair Ron Wyden (D-OR) have proposed different ways to tax unrealized capital gains every year. Their shared goal is understandable, with trillions of dollars escaping income tax under current law. But each plan raises serious administrative and legal problems. My colleague, Rob McClelland, and I suggest a simpler,
Today’s Social Security column addresses questions about whether the 2022 5.9% COLA applies to benefits filed for after December 2021, when one child’s benefit cessation can increase another child’s benefits and when the Windfall Elimination Provision (WEP) might not be applied. Larry Kotlikoff is a Professor of Economics at Boston University and the founder and
In accelerating forgiveness of certain income-based student loans, President Biden performed minor cosmetic surgery on an atrocious system. Fortunately, there’s a simple solution: Let students and parents borrow as well as refinance their loans at the prevailing Treasury’s 30-year bond rate. In accelerating forgiveness of certain income-based student loans, President Biden performed cosmetic surgery on
The COVID-19 pandemic has had a dramatic impact on commercial real estate values, and in some cases resulted in property no longer being able to support the debt with which it is encumbered. The decrease in value of commercial property has forced many owners to restructure their debt. However, the resulting forgiveness of a portion
Timothy Noonan of Hodgson Russ LLP discusses how some states tax remote employees and the effect of temporary pandemic tax changes. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes Today International. This week: tax and remote work. In
Share to Facebook Share to Twitter Share to Linkedin A misguided group in Congress is trying to hammer out a scheme to levy tariffs on such imports as steel, cement and aluminum, whose production in certain countries supposedly causes a higher output of carbon dioxide. This episode of What’s Ahead explains why this idea is
Rich Strike’s improbable Kentucky Derby win made the owner flush, with a $1.86M purse on a horse that only cost $30,000. There were plenty of other winners too, for anyone bold and prescient enough to take a flier bet on this most unlikely of winners at Churchill Downs. The most amazing type of win would
Let’s talk about near misses. Not so long ago the Biden administration proposed a comprehensive financial account reporting regime. Some observers labeled it a domestic version of the Foreign Account Tax Compliance Act. The reference was meant to be pejorative. The proposal was eventually withdrawn. Lawmakers from both parties found something distasteful about authorizing the
In recent years there has been a significant rise in fintech businesses; businesses who use technology solutions to help deliver financial service products. Experience has shown that these businesses don’t always appreciate how to calculate the amount of UK VAT they can reclaim on their operating costs. There is often a presumption that all UK
Only The Rich Can Play: How Washington Works in the New Gilded Age by David Wessel became a must read for me after a favorable review by Edward W. De Barbieri. I was hoping for it to be comparable to Showdown at Gucci Gulch, the great account of the passage of the Tax Reform Act
There are crises that government rallies to solve—usually because surveys of the population show rising anger and concern and elected officials like to retain that first half of the descriptive term. But there is a host of issues that are deemed less important because they don’t necessarily cross the consciousness of most voters. This is
In March, “China Wealth” profiled MBP as a successful New York-based accounting company in China that is now on the move in Southeast Asia with plans to open an office in Singapore this month. (See link here.) It currently has about 150 staff and five offices in China. Marcum LLP (ranked No. 15 by Accounting
A group of private equity firms, companies (including Harley Davidson – employee owners) , pension funds and nonprofits – spearheaded by Pete Stavros a partner at KKR KKR — has announced that they are creating an initiative they have titled “Ownership Works” that will work to encourage companies to have their employees – especially low-income
David Morse of the Coalition for a Prosperous America and Martin A. Sullivan of Tax Notes discuss what the United States’ tax response to Russia’s invasion of Ukraine should be. This transcript has been edited for length and clarity. Watch the shortened video here. For the full interview, watch the video below. Robert Goulder: Hello
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