Tax Law Updates

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Klauer v. Commissioner: Step Transaction Doctrine Does Not Apply to Multi-Step Bargain Sales to Charity

By H. Jacob Lager of Zuber & Taillieu LLP

The Tax Court has held that the step transaction doctrine did not apply to a series of bargain sales from a family-owned S Corp. to a charitable organization. As a result, the shareholders were entitled to charitable contribution deductions related to the sales. In William R. Klauer v. Commissioner of… More...

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Proposed Regulations Expand the Use of Electronic Payment System and Discontinue Paper Coupons Next Year

IRS Proposed Regulations to Expand the Use of Electronic Payment System  |  REG 153340-09; Issue Number: IR-2010-092  |  8/20/2010

Consistent with a Financial Management Service initiative announced in April of this year, the Internal Revenue Service (“IRS”) has issued proposed regulations to significantly increase the number of electronic transactions between taxpayers and the federal government. More...

TIGTA Report: IRS Needs to Improve Its Information System to Protect Taxpayer Data

TIGTA’s Final Audit Report on Taxpayer Data Used at Contractor Facilities  |  Reference Number: 2010-20-051  |  5/18/2010

Internal Revenue Service (“IRS”) procedures do not identify all contractors who process, store or house confidential taxpayer information at their facilities, thereby placing such data at risk for unauthorized access or disclosure, according to a Final Audit Report released by the Treasury Inspector General for Tax Administration (“TIGTA”). More...

National Taxpayer Advocate Submits Mid-Year Report to Congress; Identifies Priority Challenges and Issues for Upcoming Year

National Taxpayer Advocate’s FY 2011 Objectives Report to Congress  |  No. IR-2010-083  |  7/7/2010

The National Taxpayer Advocate has released a report to Congress that identifies the priority issues the Taxpayer Advocate Service (TAS) will address during the coming fiscal year. More...

Reinstatement of Superfund “Polluter Pays” Tax Strongly Sought in the Aftermath of Gulf Oil Spill

Reinstatement of Superfund “Polluter Pays”Tax  |  No. _____  |  6/21/2010

The U.S. Environmental Protection Agency (“EPA”) has asked Congress to reinstate the lapsed Superfund “polluter pays” taxes. More...

IRS Releases Tax Bulletin on Exclusion of Physical Injury or Sickness from Gross Income

Notice of Proposed Rulemaking Damages Received on Account of Personal Physical Injuries or Physical Sickness  |  REG-127270-06  |  2/8/2010

The Internal Revenue Service (“IRS,” or “Service”) has issued an Internal Revenue Bulletin that bears the title “Notice of Proposed Rulemaking Damages Received on Account of Personal Physical Injuries or Physical Sickness.” More...

Treasury Dep’t Releases Green Book on 2011 Tax Revenue Proposals, as PwC Issues Comments on Int’l Tax Policy Changes

Green Book of the Department of the Treasury – General Explanations on the International Tax Policy under the 2011 Budget  |  Fiscal Year 2011 Budget  |  2/1/2010

The U.S. Department of the Treasury has issued its “Green Book,” formally known as the “General Explanations of the Administration’s Fiscal Year 2011 Revenue Proposals.” More...

Treasury Department Recommends Changes to Tax Code Section 529 College Savings and Tuition Plan

Analysis of Section 529 College Savings and Prepaid Tuition Plans  |  Amendments to Section 529  |  9/10/2009

September 9, 2009 report issued by the Department of Treasury (”Department”) discussed the benefits of 529s as a way to build savings for this critically important investment, the extent to which Section 529 plans serve various income groups, and how well the plans keep costs low so as to maximize returns to savers. More...

IRS Proposes Regulations on Reporting Sales of Securities by Brokers

Basis Reporting by Securities Brokers and Basis Determination for Stock  |  26 CFR Parts 1, 31, and 301, (REG-101896-09)  |  12/17/2009

The Internal Revenue Service (“IRS”) has issued proposed regulations relating to reporting sales of securities by brokers and determining the basis of securities. More...

IRS Issues Proposed Regulations on Reporting Requirement for Payment Card and Third-Party Payment Transactions

Information Reporting for Payments Made in Settlement of Payment Card and Third Party Network Transaction  |  26 CFR Parts 1, 31, and 301; REG-139255-08; RIN 1545-BI51  |  11/23/2009

The Internal Revenue Service (:IRS”) has issued proposed regulations under a new statute requiring that, starting with transactions in calendar year 2011, the gross amount of payment card and third-party network transactions be reported annually to participating merchants and the IRS. More...

IRS Releases 2009 IRPAC Advisory Report

2009 Information Reporting Program Advisory Committee Public Report  |  IR-2009-097  |  10/28/2009

The Information Reporting Program Advisory Committee (“IRPAC”) has released the advisory group’s 2009 recommendations on a wide range of tax administration issues. More...

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Companies Mentioned

Tax Law

The following companies are mentioned in Tax Law Updates:

Internal Revenue Service

Swallows Holding, Inc.

The State of New York

New York State Department of Taxation and Finance

Amazon.com LLC

Amazon Services, LLC

Agere Systems, Inc. f.k.a. Lucent Technologies, Inc.

Detroit Medical Center

Department of Justice

Santini Stone LLC

City of Chicago

StubHub, Inc.

Mayer Brown LLP d.b.a. Mayer, Brown, Rowe & Maw LLP

Textron Inc.

County of Los Angeles

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