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1. New IRS rules simplify compliance for money market fund shares   WebExclusive

BY Sally P. Schreiber, J.D.
In response to new SEC pricing rules for shares in certain money market funds (MMFs), the IRS on Wednesday issued guidance that allows a simplified method for calculating gain or loss on shares in MMFs subject to the new rules and exempts redemptions of shares in these MMFs from the wash sale rules.As the Treasury explained in its announcement on the new rules, “These particular MMFs will no longer be able to utilize the special exemptions that currently allow them to maintain a stable net asset value (NAV), and instead the share price will float, so the

2. Final rules issued on bona fide indebtedness and terminating partnership’s startup expenses   WebExclusive

BY Sally P. Schreiber, J.D.
On Tuesday, the IRS issued T.D. 9682, which finalized proposed regulations relating to basis of indebtedness of S corporations to their shareholders that provide that S corporation shareholders increase their basis of indebtedness of the S corporation to the shareholder only if the indebtedness is bona fide, which is determined under general Federal tax principles and depends upon all of the facts and circumstances.

3. Federal courts disagree on health care credits for federal exchanges   WebExclusive

BY Sally P. Schreiber, J.D.
The appellate courts for the D. C. Circuit and the Fourth Circuit issued conflicting decisions on Tuesday regarding the availability of the Sec. 36B premium tax credit for taxpayers who purchase health insurance on exchanges set up by the federal government. The D.C Circuit held that the regulation permitting taxpayer’s to get premium tax credits under Sec.

4. New rules on covered asset acquisitions will shut down transactions to avoid Sec. 901(m)   WebExclusive

BY Sally P. Schreiber, J.D.
In Notice 2014-44, the IRS announced that it would issue regulations to prevent taxpayers from misapplying the statutory disposition rule in cases where the gain or loss from the disposition of the relevant foreign asset (RFA) is recognized for U.S. income tax purposes but not for foreign income tax purposes.

5. Definitions of R&E expenditures are amended under final rules   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS issued final regulations on which amounts paid or incurred in connection with the development of tangible property, including pilot models, qualify for the Sec. 174 deduction (or amortization) for research and experimental expenditures (T.D. 9680). The regulations finalize proposed rules issued last September (REG-124148-05), with a few changes in response to comments.

6. Effective date of fiduciary fee unbundling rules delayed until 2015   WebExclusive

BY Sally P. Schreiber, J.D.
In response to a comment that the current effective date of the new rules on fiduciary fees does not give fiduciaries enough time to implement them, the IRS amended T.D. 9664 to delay the date. As a result, the new rules governing which costs of trusts and estates are subject to the 2% floor on miscellaneous deductions now apply to tax years beginning after Dec.

7. Court halts IRS regulation of contingent fees for refund claims   WebExclusive

BY Alistair M. Nevius, J.D.
The U.S. District Court for the District of Columbia granted a motion of summary judgment and issued an injunction to prevent the IRS from regulating contingent fee arrangements for the preparation and filing of ordinary refund claims under Circular 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R.

8. Partnership interest expense allocation rules are finalized   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS has finalized, without substantive changes, proposed regulations that were issued in conjunction with temporary regulations in January 2012. The final regulations make permanent four changes to the rules for allocating and apportioning interest expense for partners in partnerships (T.D. 9676). The first change is to the method for apportioning interest expense for corporate partners whose interest in the partnership is 10% or more.

9. AICPA sues IRS to stop return preparer program   WebExclusive

BY Alistair M. Nevius, J.D.
The AICPA filed suit in the U.S. District Court for the District of Columbia on Tuesday, asking the court to halt the IRS’s recently introduced Annual Filing Season Program. The AICPA’s three-count complaint asks the court to declare the rule implementing the program unlawful and stop its operation.The Annual Filing Season Program, introduced June 30 in Rev.

10. Fighting identity theft, IRS issues final rules on truncated identification numbers   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS issued final regulations (T.D. 9675) that allow the use of truncated taxpayer identification numbers (TTINs) on payee statements and certain other documents where not prohibited by the Internal Revenue Code, applicable regulations, or other guidance published in the Internal Revenue Bulletin, forms, or instructions. The regulations finalize the proposed rules issued in 2013 (REG-148873-09) with a few significant changes and make permanent a pilot program under Notice 2011-38 that is obsolete now that the final regulations have been published.A filer is a person required to report a transaction (i.e., payment, distribution, or transfer) with another
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