Quid Pro Quo: Charity Disclosure Requirements
Section 6115 imposes a disclosure requirement on charitable organizations that receive quid pro quo contributions in excess of $75. A quid pro quo…
Recent National Articles about North Carolina Tax Matters
There have been several recent national articles about North Carolina tax matters. 1. The May 11, 2022 issue of Taxes – The Tax Magazine has an article…
Golden Parachute Payments – Shareholder Approval Exception
Sections 280G and 4999 impose a 20% excise tax in addition to regular income taxes on individuals who receive an excess parachute payment upon a change of…
The Tax Section Returns to Kiawah Island for Memorial Day!
After a 3-year hiatus, the Tax Section returns to beautiful Kiawah Island, SC for its annual meeting and CLE program, May 27-29, 2022. The 3-day program…
New Proposed Rules for Group Tax Exemptions
Section 501(a) provides an exemption from income taxation for certain organizations. For decades, the IRS has provided a procedure allowing multiple…
Federal Income Tax Update: Part II
I. IRS Continues to Crack Down on S Corporation Disguised Wages. In Ward & Ward Company v. Commissioner, T.C. Memo. 2021-32, the Tax Court held payments…
Federal Income Tax Update
Tax Court Again Rules Emotional Distress is Not Physical Illness. In Tressler v. Commissioner, T.C. Summ. Op. 2021-33, the Tax Court held emotional distress…
Marketable Securities as Money Under Partnership Tax Rules
Section 731(c) generally treats marketable securities as money in determining gain or loss on a distribution to a partner. Section 731(a)(1) provides no gain…
OAH Tax Case Records Become Available to the Public
On November 1, 2021, the Chief Judge of the Office of Administrative Hearings, Donald van der Vaart, issued a memorandum announcing all OAH records of every…
Penalty Waiver for Failure to Pre-Pay Penalties
The most common penalties assessed by the IRS are the failure to file and failure to pay penalties under Section 6651. However, another common penalty is the…