CURRENT EDITION

When Your Client’s World Is Bigger Than the U.S.
A lot of client meetings still start with the same assumptions: W-2 in a U.S. state, mortgage nearby, a 401(k), maybe some RSUs, and a college-savings plan. Yet many of those “simple” clients now own an apartment in another country, freelance for a foreign company, or have parents wiring money from overseas. The tax code does not see those details as background color; it treats them as organizing facts. This is where citizenship, residency, and domicile quietly step onto center stage. For planners, the challenge is not memorizing every cross-border rule. It is knowing when a client is no longer “just domestic” and shifting your planning framework before you stumble into penalties, double taxation, or blown opportunities.
READ MOREBuying Tax Credits: Inflation Reduction Act
Tax shelters offered high income taxpayers an easy way to reduce and even eliminate federal income taxes at the individual level. The growing tax avoidance schemes, many questionable in nature, threatened to collapse the U.S. tax system. Hence the need for tax reform and the Economic Recovery Tax Act of 1981 (ERTA). New rules cannot keep a tax professional down. Real estate was once again the favorite tool for reducing taxes. Enter cost segregation. Couple that with bonus depreciation and the automatic change of accounting method using Form 3115 , and you have a recipe for serious tax reduction. The tax shelters of the 1970s were often questionable. Cost segregation is still a valid way to accelerate deductions for income property owners. But none of that compares to the tax benefits available under the Inflation Reduction Act of 2022 (the IRA).
Read MoreShould You File Your Client’s Taxes Early?
Common sense says that filing taxes as early as possible in the year gets an onerous chore off your plate and, chances are, gets your clients’ tax refund into their pockets quicker. Common sense can also be wrong if you need, as most taxpayers do, various tax-reporting forms that can arrive in early spring, if not later. There are also many other reasons you may, or may not want, to file your client’s taxes as early as possible.
Read MoreHarnessing ChatGPT with “BEST WILD”
In the realm of tax research, the journey from traditional methods to the digital age has been transformative. The evolution of AI in this field marks a significant milestone, reshaping how tax professionals approach complex regulations and compliance. This journey began with simple tax software, gradually advancing to more sophisticated AI tools capable of analyzing large datasets and identifying patterns beyond human capability. Today, we stand at a pivotal moment where AI, particularly ChatGPT, is not just an aid but a game-changer in tax research. Enter "BEST WILD", a revolutionary technique designed specifically for this new era. By integrating the advanced capabilities of ChatGPT, "BEST WILD" offers a systematic approach that transcends traditional boundaries in tax law analysis. This method doesn’t just aid in navigating the complexities of tax regulations; it revolutionizes the process, making it more efficient, accurate, and insightful.
Read MoreLessons From Surprising Items Buried in 2023 Tax Developments
Various rulings and tax agency actions in 2023 were arguably “unusual” and “surprising.” Most of these items were not the key holding of court decisions or IRS news releases or guidance. They were more subtle or buried. This article uncovers a variety of these oddities and posits what we might learn from them.
Read MoreTAX COURT ROUNDUP – FEBRUARY 2024
New year, new rules, the changing features of United States Tax Court practice and procedure confront the tax practitioner (even those who don't practice in Tax Court themselves), who must keep current among all the demands on our time, especially as the season opens. Let's jump in.
Read MoreBONUS CLIENT ALERTS – Assessing the Impact of New Tax Legislation
The House recently approved new tax legislation, some of which applies retroactively to 2023. Reliable reports suggest that the Senate likely won't vote on their version of the bill until later this month or possibly in March due to a two-week recess starting on 02/12/2024 – if they even approve it at all. Should the legislation pass, that would mean that there has been only one filing season (2023) in the last five (2020-2024) where tax law changes and other issues have not affected the filing season. We know that these sorts of changes have huge implications for the timing of service you can offer your clients, as well as the price you may need to charge for your work.
Read MoreDid the Other Shoe Just Drop on Last Year’s IRS alliantgroup Raid?
Lane Grigsby is back in the “news” as one of the major backers and advisers of Louisiana Governor Jeff Landry, but that’s not what gets the chairman of Cajun Construction in Think Outside the Tax Box. For that, we have a recent decision in the United States Court of Appeals for the Fifth Circuit. Judge Patrick Higginbotham wrote the opinion, and it’s all about the research credit.
Read MoreA Winner of a Losing Hobby Case
Wolfgang Frederick Kraske, representing himself in Tax Court, pulled off a rare feat. He managed to get two opinions for the price of one in a relatively low stakes case . My friend Lew Taishoff found the regular decision about the $4,574 Section 6662(a) accuracy related penalty to be of great interest . I think the more interesting story is in the memo opinion that covers the tax deficiency of $22,687 for the years 2011 and 2012. It is mostly about Section 183: Activities not engaged in for profit, commonly referred to as the hobby loss rule. Although in this case, the activity does not even seem to get up to the level of a hobby, much less a business conducted for profit. I didn’t dig any deeper into the case, so the story you are getting is what Judge John H. Gale concluded. Kraske might have had something to say if I had interviewed him.
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CURRENT EDITION

When Your Client’s World Is Bigger Than the U.S.
A lot of client meetings still start with the same assumptions: W-2 in a U.S. state, mortgage nearby, a 401(k), maybe some RSUs, and a college-savings plan. Yet many of those “simple” clients now own an apartment in another country, freelance for a foreign company, or have parents wiring money from overseas. The tax code does not see those details as background color; it treats them as organizing facts. This is where citizenship, residency, and domicile quietly step onto center stage. For planners, the challenge is not memorizing every cross-border rule. It is knowing when a client is no longer “just domestic” and shifting your planning framework before you stumble into penalties, double taxation, or blown opportunities.

Are You Committing Filing Status Malpractice?
Consider this article your periodic reminder that, for married taxpayers, filing jointly is an election and not the default (and certainly not the only) filing status option. It is important in a busy practice to remember to offer this option to clients who may benefit from filing separately, even if they don’t ask.

Syndicated Easements: Fresh IRS Offer and the Perils of Post-BBA Gamesmanship
The IRS has issued a statement about a new settlement offer that is going out for conservation and historic preservation easement disputes. It is similar to previous offers, but there is one big difference. The partnership will not have to make a payment at the time that it accepts the offer. Other than that, it is similar to the deal offered in 2020. Taxpayers get to deduct what they are out-of-pocket as an ordinary deduction and are subject to a 10% penalty. In general, the out-of-pocket donation might be around 20% to 25% of the claimed charitable deduction. The Tax Court, on average, has been allowing 6%, although results vary. There is usually a 40% penalty in the decided cases.








