The State Department is barred from issuing a passport to any individual who has a seriously delinquent tax debt, and may revoke a passport previously issued to such an individual. The IRS Commissioner certifies tax delinquent status for this purpose. Notice, revocation of certification, and hardship exception rules apply. A seriously delinquent tax debt is… Read More


Currently, owners of partnerships, S corporations, and sole proprietorships – as “pass-through” entities – pay tax at the individual rates, with the highest rate at 39.6 percent. The highest rate is reduced to 37 percent under the Tax Cuts and Jobs Act. The Act also allows a temporary deduction in an amount equal to 20… Read More


Find out how to calculate days spent in the United States and days spent abroad to determine qualification for the foreign earned income exclusion. By Allen Schulman March 8, 2018 Generally, U.S. citizens and resident aliens are taxed on their worldwide income. However, under Sec. 911, Citizens or Residents of the United States Living Abroad,… Read More


In general, any amount that is converted (or rolled over) from an eligible retirement plan to a Roth IRA is includible in gross income as a distribution for the tax year in which the amount is distributed or transferred from the eligible retirement plan. 5 See §24,450 for the rules on taxation of distributions. In… Read More


Taxpayers can make qualified rollover contributions to a Roth IRA ( ¶2171) from another Roth IRA, a traditional IRA ( ¶2155), and from certain qualified retirement plans ( Code Sec. 408A(c)(6) and (e)). 175 However, unlike rollovers to traditional IRAs ( ¶2145), qualified rollovers to Roth IRAs may result in the rollover being included in… Read More


To be treated as an S corporation, a corporation must elect S corporation status by filing Form 2553, Election by a Small Business Corporation. Reg. §1.1362-6(a)(2)(i). Compliance Note Form 2553 may also be used to file shareholder consents ( Reg. §1.1362-6(b)(3)(i)) and to select a tax year. Reg. §1.1378-1(e). It is clear that Form 2553… Read More


The deductibility of miscellaneous itemized deductions is temporarily repealed for tax years 2018 through 2025. Background Certain itemized deductions of an individual are treated as miscellaneous itemized deductions and are only allowed to the extent that their total exceeds two percent of the individual’s adjusted gross income (AGI) (Code Sec. 67(a); Temp. Reg. §1.67-1T). The… Read More


Traditionally, tax law provides numerous incentives for home ownership by allowing the deduction for mortgage interest and real estate tax. The Tax Cuts and Jobs Act modifies these popular tax benefits. Mortgage Interest Home mortgage interest is generally deductible if it is paid or accrued on acquisition indebtedness or home equity indebtedness secured by any… Read More


Reg. § 1.368-2 does not reflect P.L. 94-455, P.L. 96-589, P.L. 97-248, P.L. 98-369, P.L. 99-514 or P.L. 100-647. (b)(1)(i)Definitions.— For purposes of this paragraph (b)(1), the following terms shall have the following meanings: (A)Disregarded entity.— A disregarded entity is a business entity (as defined in § 301.7701-2(a) of this chapter) that is disregarded as… Read More


Re: 2017 Tax Cuts Act: What it Means For Businesses The Tax Cuts and Jobs Act was signed by President Trump on December 22. The Act makes sweeping changes to the U.S. tax code and impacts virtually every taxpayer. For businesses, tax benefits include a reduction in the corporate tax rate, increase in the bonus… Read More