Feature Article Archives - Think Outside the Tax Box

Feature Article

By Joshua Youngblood

IRC Section 121 Exclusion: Nuances That Make a Big Difference

With the sale of a client’s primary residence, many tax professionals are familiar with the Section 121 exclusion, which allows taxpayers to exclude up to $500,000 ($250,000 for single - $500,000 for married filing jointly) on capital gains for the sale. Often, the only criteria mentioned is that the taxpayer must have owned and occupied the home for two of the most recent five years. However, this barely scratches the surface of Section 121; there’s much more money-saving potential in this portion of the tax code.

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The Wild West of Employee Retention Credits (ERC): Outlaws, Deputies, and Cowboys

Gather 'round, pardners! The Employee Retention Credit (ERC) has been the latest gold rush in the tax frontier, drawing business owners, tax deputies, and even a few sly outlaws. But as the dust settles, the IRS—our law keeping sheriff—is on the hunt for any who might’ve bent the rules. In this frontier of finance, knowing who’s who can keep you out of trouble as the IRS rounds up dubious claims.

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Striking a Balance: Pitching to the Umpires of Tax Law – Understanding US Tax Court Judges through the Art of Baseball Analogies

In this fascinatingly original article, we explore the striking parallels between America's pastime and the high-stakes world of tax litigation. Prepare to be surprised as we reveal the hidden connections between the umpires of the diamond and the judges of the Tax Court. From the precise strike zones of regular judges to the veteran expertise of senior judges, and the specialized skills of special trial judges, you'll gain a newfound appreciation for the officials who keep the game of tax law fair and balanced.

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Navigating IRS Penalty Relief and Forgiveness

Yes, the IRS does forgive some tax penalties. The IRS refers to this forgiveness as penalty abatement. Abatement is the act or process of reducing or removing something. In this case it is removing or reducing a penalty. But penalty forgiveness is not a blanket offer that everyone qualifies for the way the radio ads make it seem. There is a process that the IRS has for requesting and granting abatement. It is up to the taxpayer to prove that they qualify for abatement. That’s where you come in.

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Popular Tax Shelter for the Ultra-Wealthy Comes onto the Radar

In a recent turn of events that has caught the attention of financial experts and policymakers alike, Senate Finance Committee Chairman Ron Wyden, D-Ore., has unveiled the results of an 18-month investigation into the use of Private Placement Life Insurance (PPLI) by the ultra-wealthy. The investigation, the first of its kind focusing on PPLI, highlights the use of these policies as a significant tax shelter mechanism, revealing the ways in which a small number of wealthy individuals are leveraging them to avoid substantial tax liabilities.

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Kovel: Attorney-Client Privilege for Tax Professionals

Twice in my four-decade career, two special agents from IRS Criminal Investigation (CI) entered my office armed with a search warrant, firearms at their side. In both cases, it started the same way.

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The Hidden Benefits of Private Placement Life Insurance (PPLI) for High-Net-Worth Families

For wealthy families, the world of finance can feel like a high-stakes chess game. With increasing state and federal income tax rates, new tax laws on the horizon, and the complexities of private investments like hedge funds, finding ways to grow and transfer wealth efficiently is more important than ever. Enter life insurance—a tool not just for its traditional role of providing death benefits but as a strategic ally in tax-efficient wealth management. In particular, Private Placement Life Insurance (PPLI) offers unique advantages that make it a worthy consideration for those with sophisticated financial needs and significant liquidity.

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Tax Principles Analysis of the Celsius Bankruptcy

In Matt Metras’ excellent article on tax reporting for clients who receive settlements from the Celsius bankruptcy, he says “It’s unclear if this section could apply to digital asset bankruptcies for a variety of reasons outside the scope of this article.” Matt provides an example of the IRS’ preferred method of accounting for settlement proceeds as published on the Taxpayer Advocate’s website. Matt also notes that the TAS tax tip lacks any citations to substantial authority. It may or may not be taxpayer friendly. The articles published by many cryptocurrency exchanges are also citation free and, after a cursory review, seem geared in a larger sense toward helping exchange users account for the settlement accurately on the exchange itself. In this article, I would like to look at the forest of tax law principles that the Celsius bankruptcy settlement puts into play rather than any specific tax reporting tree. Welcome to the jungle.

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Converting to Fahrenheit: Tax Implications of the Celsius Bankruptcy

Why is the freezing point of water 32 degrees? It was a fairly arbitrary decision made by inventor Daniel Gabriel Fahrenheit in 1724 and demonstrates that Americans will do just about anything to avoid using the metric system. But this isn’t a story about Fahrenheit, it’s about Celsius. Celsius was a major cryptocurrency exchange founded in 2017, which at its peak had over $12 billion in assets under management. Celsius declared Chapter 11 bankruptcy on July 13, 2022. Celsius found itself caught up in the major crypto collapse of 2022...

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