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TaxCourtBlog
The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.
The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.
Understanding the critical distinction between grantor and non-grantor trusts, their tax consequences, and the factual elements that determine classification. This guide explores the tradeoffs between tax treatment and asset protection.
Understanding Intentionally Defective Grantor Trusts (IDGTs), their purpose in estate planning, and how they are structured to achieve both estate tax exclusion and income tax advantages while maintaining asset protection benefits.
Understanding the critical tradeoffs between probate avoidance, estate tax minimization, and basis step-up benefits in trust and estate planning. This guide explores how different strategies balance these competing objectives.
Exploring the emerging intersection of blockchain technology, smart contracts, and trust law. This guide examines how wallet addresses can serve as trust identities, hardware security modules (HSMs) as trustees and beneficiaries, and the tax treatment and asset protection possibilities in the digital asset era.
Tax credit and exclusion for qualified adoption expenses
Tax treatment of alimony payments and separate maintenance payments
Deductions for ordinary and necessary business expenses under Section 162
Section 163(j) limitations on business interest deductions under the TCJA
Tax treatment of canceled, forgiven, or discharged debt
What constitutes a capital asset and how capital gains and losses are taxed
Short-term vs long-term capital gains and losses and their tax treatment
Deduction for losses from casualty or theft of property
Deduction for contributions made to qualified charitable organizations
Tax credit for expenses paid for the care of qualifying children and dependents
Tax credit for qualifying children and dependents
This guide covers tax law, accounting services, and business consulting to help optimize tax strategy and business operations.
When income is considered received for tax purposes under constructive receipt doctrine
Tax credit for taxpayers age 65 or older or who are retired on permanent and total disability
Refundable tax credit for low to moderate income working individuals and families
Tax credits for qualified education expenses including American Opportunity and Lifetime Learning Credits
Exclusion from income for meals and lodging provided for employer convenience
Tax credit for qualified energy efficient improvements to your home
Filing taxes is a responsibility that many individuals and businesses face each year. However, there are instances when taxpayers fail to file their income tax returns, leading to various complicat...
What constitutes gross income and must be reported for tax purposes
IRS rules for deducting expenses related to business use of a home
When navigating the complexities of tax liabilities, particularly in the context of marriage and divorce, the Innocent Spouse Program provides crucial relief options for individuals who find themse...
International tax litigation has gained prominence in today's global economy, where cross-border transactions, foreign investments, and international financial obligations are commonplace. This gui...
Deductions for expenses incurred in the production or collection of income
Receiving notification of an IRS audit can be a daunting experience for many taxpayers. The complexities of tax law and the potential implications of an audit often lead to feelings of anxiety and ...
The IRS uses various methods to collect unpaid tax liabilities, including federal tax liens, levies, and other enforcement measures. This guide explains IRS collection procedures, taxpayer rights, collection alternatives, and Collection Due Process (CDP) hearings.
Rules for deferring capital gains taxes through like-kind exchanges
Deductions for qualified medical expenses including pet care in certain circumstances
Rules for miscellaneous itemized deductions subject to 2% AGI floor
Deduction for qualified home mortgage interest paid on primary and secondary residences
Deduction for qualified moving expenses (limited after 2017 for most taxpayers)
Additional tax on net investment income for high-income taxpayers
Rules limiting deductions from passive activities including rental real estate
The IRS may impose penalties for non-compliance with tax regulations, which can significantly increase the total amount owed. Penalty abatement allows taxpayers to eliminate or reduce certain penalties under qualifying circumstances.
Taxation of distributions from pensions and annuities
Rules governing the taxation of passive foreign investment companies and qualified electing funds
Refundable tax credit to help pay for health insurance purchased through the Health Insurance Marketplace
Tax credit for qualified expenses for residential energy efficient property improvements
Rules governing Roth Individual Retirement Accounts and distributions
Tax credit for contributions to retirement accounts for low to moderate income taxpayers
Mark-to-market accounting rules for futures, options, and other Section 1256 contracts
Election to expense certain depreciable business assets immediately
How Social Security benefits are taxed based on provisional income
Deduction for state and local income, sales, and property taxes
IRS wage garnishment allows the IRS to seize a portion of your wages directly from your paycheck to satisfy unpaid tax debts. This guide explains how wage garnishment works, your rights, and strategies to stop or mitigate these actions.
Deduction for interest paid on qualified student loans
Controlled foreign corporation income inclusion rules under Subpart F
Tax issues can be overwhelming and stressful, whether you're an individual grappling with personal tax debt or a business facing financial pressure from tax obligations. Fortunately, numerous tax r...
Understanding tax defense strategies, relief options, and how to effectively resolve disputes with the IRS. This guide covers audit defense, penalty abatement, collection alternatives, and when to seek professional representation.
Tax promoter defense is a crucial area of tax law that addresses the legal protection of individuals and entities involved in promoting tax-related strategies and shelters. This comprehensive guide...
Tax shelters are financial strategies designed to minimize tax liabilities, but they can also lead to complex legal issues and government scrutiny. Tax shelter litigation refers to the legal disput...
Currently Non-Collectible CNC status is a designation provided by the IRS for taxpayers who are experiencing financial hardship and are unable to pay their tax liabilities. This status essentially ...
State and local taxes often referred to as SALT are essential components of the overall tax framework in the United States. These taxes can vary significantly from one jurisdiction to another, maki...
Tax court litigation plays a crucial role in the American tax system, providing a venue for taxpayers to contest disputes with the Internal Revenue Service IRS regarding tax liabilities, penalties,...
Tax treatment of unemployment benefits and compensation
IRS rules preventing the deduction of losses from wash sales in securities trading
Understanding IRS listed transactions, which are specific tax avoidance schemes that require mandatory disclosure and carry significant penalties
Understanding IRS reportable transactions, including Transactions of Interest, and their disclosure requirements
Identity thieves use stolen Social Security numbers to file fraudulent tax returns and claim refunds. Learn how to recognize identity theft tax fraud, what to do if you're a victim, and how the IRS protects innocent taxpayers from erroneous tax bills and collections.
Learn what Qualified Small Business Stock (QSBS) is, how Section 1202 tax benefits work, eligibility requirements, and exclusion percentages. Complete guide to QSBS tax benefits.
How is QSBS basis calculated and what are the holding period requirements? Learn about basis adjustments, holding period rules, and Section 1223 tacking.
Can carried interest holders claim QSBS benefits? Learn about Section 1202(g) requirements, capital interest limitations, and how profits interests affect QSBS exclusions.
What are common QSBS mistakes and how to avoid them? Learn about acquisition errors, holding period issues, corporate qualification problems, and documentation requirements.
Common questions about Qualified Small Business Stock (QSBS) and Section 1202 tax benefits. Answers to frequently asked questions about QSBS eligibility, exclusions, and requirements.
What limitations and restrictions apply to QSBS? Learn about per-issuer limits, holding period requirements, active business requirements, and other QSBS restrictions.
How does QSBS work when held through a partnership? Learn about Section 1202(g) pass-through treatment, partnership rollovers, and capital interest limitations.
What strategies can maximize QSBS tax benefits? Learn about investment timing, holding period planning, multiple issuer strategies, and estate planning with QSBS.
What have Private Letter Rulings said about QSBS issues? Learn about Section 1045 late election relief, Section 1202 qualification determinations, and IRS guidance on QSBS.
What recent changes affect QSBS eligibility and benefits? Learn about OBBBA changes, the July 4, 2025 applicable date, increased asset thresholds, and new exclusion percentages.
How do you report QSBS sales and exclusions on your tax return? Learn about Form 8949, Schedule D, and proper reporting of Section 1202 exclusions.
How must QSBS stock be acquired? Learn about original issue requirements, redemption restrictions, and what disqualifies stock from QSBS treatment.
Can QSBS status be preserved through transfers, gifts, or corporate reorganizations? Learn about Section 1202(h) rules for transfers and conversions.
What makes a corporation a qualified small business for QSBS purposes? Learn about the $75 million asset test, active business requirements, and excluded industries.
Can you defer QSBS gains by rolling over into new QSBS? Learn about Section 1045 rollovers, 60-day replacement window, partnership rules, and capital interest limitations.
How much capital gains can be excluded under Section 1202? Learn about QSBS exclusion percentages, holding period requirements, per-issuer limits, and basis considerations.
When tax preparers or accountants commit fraud, their clients are typically victims, not criminals. Learn about tax preparer fraud schemes, how the IRS protects innocent clients, when clients might face civil penalties, and what to do if your tax preparer commits fraud.
Understanding CFC (Controlled Foreign Corporation) reporting requirements for U.S. shareholders. Learn about Form 5471 filing obligations and Subpart F income reporting.
Understanding cryptocurrency tax obligations. Learn how the IRS treats cryptocurrency transactions, when to report gains and losses, and common reporting mistakes to avoid.
Understanding FATCA (Foreign Account Tax Compliance Act) requirements for U.S. taxpayers with foreign accounts. Learn about Form 8938 filing requirements and FATCA's impact.
Understanding FBAR (Foreign Bank and Financial Accounts Report) requirements. Learn who must file, when to file, and the consequences of non-compliance.
Clarifying the tax treatment of tips. Learn when tips are taxable, how to report tip income, and common misconceptions about tip taxation.
Understanding new tax and reporting obligations under the Corporate Transparency Act (OBBBA). Learn about beneficial ownership reporting requirements and their implications.
Learn about Offers in Compromise (OIC) - how to settle your tax debt for less than the full amount owed. Understand eligibility, the application process, and what the IRS considers.
Understanding IRS installment agreements and payment plans. Learn how to set up a payment plan to pay your tax debt over time, including short-term and long-term options.
Understanding PFIC (Passive Foreign Investment Company) reporting requirements. Learn about Form 8621, excess distributions, and the tax treatment of PFIC investments.
Overview of California sales tax rules, exemptions, and compliance requirements for businesses operating in California.
Comprehensive guide to Controlled Foreign Corporation (CFC) tax rules, Subpart F income, and how to navigate CFC compliance requirements with the IRS.