Frank Aragona Trust v. Commissioner
The Net Investment Income Tax is imposed on investment income over certain thresholds. In a number of earlier articles, Baker Newman Noyes has addressed various aspects of the Net Investment Income Tax
The Net Investment Income Tax is imposed on investment income over certain thresholds. In a number of earlier articles, Baker Newman Noyes has addressed various aspects of the Net Investment Income Tax
For most people, the answer to this question is clear. They own a single home, and spend most of their time living and working in the same state. For others, the answer may not be so clear, at least as it relates to taxes. This can create both tax pitfalls and opportunities.
This year the IRS issued final regulations under IRC Section 67 addressing the application of the 2% floor on miscellaneous itemized deductions to estates and non-grantor trusts. The final regulations were issued originally as effective for tax years beginning or after May 9, 2014. The regulations were subsequently amended, however, to be effective for tax years beginning on or after January 1, 2015.
The American Institute of Certified Public Accountants (AICPA) held its annual National Conference on Banks and Savings Institutions in National Harbor, Maryland on September 8th – 10th. With more than 1,500 attendees and dozens of sessions and renowned speakers, the conference provided updates on economic, accounting, regulatory and financial reporting issues. The speakers included prestigious economists, and officials from standard setting bodies and regulatory agencies.
For banks who have not “conformed” – i.e. made the bad debt conformity election – a recent IRS issuance puts them on more or less equal footing with those who have. The conformity election provides that if the tax deduction for charge-offs matches the book charge-off amount, the IRS will not challenge the tax deduction.
Many foreign (non-U.S.) businesses are selling to customers within the U.S. These companies conduct various activities within the states, and one often overlooked (or ignored) topic is state taxes.
In our September newsletter, we introduced the topic of sales tax in the age of e-commerce and traced developments over the last two decades from the initial rise of internet sales of tangible property by companies such as Amazon to the more recent cloud computing revolution. We discussed the states’ evolving attempts to adapt a sales taxation system rooted in the “old world” of brick and mortar stores to the modern, ever-changing reality of e-commerce, with a specific focus on cloud computing transactions, referred to as “Software as a Service” or SaaS in tax parlance.