Tax rules are generally designed with a purpose in mind. Most rules serve to define the tax base and tax rates. Many others serve a behavioral purpose to encourage or discourage certain activities. The focus of this article stems from tax rules that are a combination of favoring certain activity such as generation of capital gains, and a limitation on such gains for certain taxpayers, such as the so-called “hot assets” rule for partners under IRC Section 751, Unrealized Receivables and Inventory Items. While Section 751 has been in the tax law for decades, a new application of it was raised by both the IRS and California FTB. This article summarizes Rawat, TC Memo 2023-14, rev’d, No. 23-1142 (DC Cir., 2024), and FTB Legal Ruling 2022-02, and offers observations on their relevance to tax research and practice.
Freelancer Deductions: What You Might Be Missing and What You Need to Remember
Joshua Youngblood
Even savvy freelancers often miss deductions that could significantly reduce tax liability. The IRS offers legitimate ways for freelancers to deduct business-related costs, but it’s not always obvious which expenses qualify and which ones cross the line into nondeductible territory. This confusion is made worse when we see some of the terrible advice from so-called “experts” on social media. In this article, we’ll explore the most commonly missed deductions for freelancers, highlight real-world examples, and review what tax professionals need to keep in mind when advising these clients.
