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Tax Blawg

Tax Talk Blog for Tax Pros

Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.

Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.

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SALT Blawg

Tax Blawg

As Democrats continue to finalize their now-$1.75 trillion tax-and-spending plan, the Federal income tax deduction for state and local taxes (the “SALT deduction”) has once again reared its head in partisan politics playing out in deliberations over a major piece of legislation.  As prior blog installments have discussed, the SALT deduction cap became a political lightning rod in 2017 when a Republican-controlled Congress passed the Tax Cuts & Jobs Act.  Four years later, here we go again.  Interestingly, for the SALT deduction’s first 150 years, it was not a partisan issue.  It ...

Categories: SALT, SALT Update

Chamberlain Hrdlicka held its 43rd Annual Tax and Business Planning Seminar over three days from November 2-4, 2021. This year’s seminar showcased virtual presentations from attorneys in each of its offices and featured a keynote presentation by the IRS Commissioner, Charles P. Rettig. The event was open to the public and had in attendance approximately 300 accountants, business finance executives, financial planners and lawyers who guide clients in tax and business matters. The detailed topic descriptions from the event can be found here.

Attendees gained valuable ...

Our three-day 2021 webinar will feature attorneys from our Atlanta, Houston, Philadelphia, and San Antonio offices presenting today's most timely Tax and Business Planning topics.

Dates and Times:

  • Tuesday, November 2 from 12:00 - 4:30 p.m. CST
  • Wednesday, November 3 from 12:00 - 4:30 p.m. CST
  • Thursday, November 4 from 12:00 - 4:30 p.m. CST

Cost: $20 per day or $50 for 3 days

To request a financial hardship discount, a written request should be sent by email to Chamberlain Hrdlicka at firm@chamberlainlaw.com.

CLE and CPE Credit:

  • Texas CPE and CLE Hours:
    • Tuesday, November 2: 4.8 CPE ...

Greek philosopher Plutarch is famous for posing the Ship of Theseus Paradox.  The mythical hero Theseus, upon sailing back to Athens after an epic battle, replaces, one-by-one, the old, decayed planks of his mighty ship with new and stronger timbers.  The thought experiment is whether the ship which has been restored by replacing each and every one of its wooden planks is still the same ship.  If not, when did it become a new ship?  When half of the planks were replaced?  When the last plank was replaced? 

In a recently issued appellate court decision, Schneider National Leasing, Inc. v. United ...

The road to obtaining a large tax refund can sometimes feel like the journey of a 1000 miles. In prior postings we have discussed the single step with which the journey typically begins – the refund claim. Today we’ll touch on a final step in the journey – review by the Joint Committee on Taxation (JCT).

Introduction to JCT’s Role in Tax Refunds

The JCT is a bicameral committee of the U.S. Congress charged with several responsibilities including the review of large tax refunds. Specifically, in the case of tax refunds in excess of $2,000,000 ($5,000,000 in the case of a C ...

On August 11, 2011, TIGTA published a report entitled ‘”Efforts to Address the Compliance Risk of Underreporting of S Corporation Officers' Compensation are Increasing, but More Action Can Be Taken.”  At the outset, TIGTA properly identified part of the problem:  there are S corporations – some owned by one individual and others owned by groups – where the officers perform work and do not pay themselves compensation. 

The S corporation is a “pass through,” so that its income would be passed through and be reported by the Officer.  However, this technique has the effect of ...

The undersigned has been practicing in the United States Tax Court since May 1971, and has seen many changes, such as the evolution of the very simple Tax Court Rules of Practice during 1973 into the Tax Court Rules of Practice and Procedure when the Court added provisions with regard to summary judgment as well as discovery.  The Tax Court, and its predecessor – the Bureau of Tax Appeals, were originally created to give taxpayers the opportunity to challenge determinations of deficiencies in taxes, and occasionally secure overpayments when in fact they were appropriate.  Over time ...

When the IRS reaches (in the words of Tax Court Judge Mark Holmes) the “we're taking your stuff” stage to collect back-taxes, taxpayers generally have the right to a collection due process (CDP) hearing at which a CDP hearings officer is duty-bound to independently and genuinely evaluate whether it’s proper for the IRS to move forward with seizing a taxpayer’s property.  On May 20, 2021, the Tax Court, in Mason v. Commissioner, concluded the IRS had abused its discretion in the CDP process when it gave the green-light to the IRS collection division to take the taxpayer’s stuff ...

London’s Underground (which is a subway to us Yanks) is known for its iconic warnings to “mind the gap.”  That’s the spatial crevice between the train and the station platform.  In D.C., a different gap is garnering attention: the tax gap.  This is the delta between taxes owed to the government and actually paid.

On May 20, 2021, as part of the Administration’s pitch for an $80 billion increase in IRS funding, Treasury released a report that outlines the magnitude and categorical causes of the tax gap, and in broad strokes how it would deploy the $80 billion over a 10-year period to ...

Section 1031 “like-kind” exchanges have long been a useful tool for family and closely held business planning. For example, business enterprises have been able to exchange commercial or industrial buildings for larger facilities without incurring current tax liability. Similarly, individuals who have owned and operated rental property but no longer are able or wish to manage such property have utilized Section 1031 to exchange their property for “net leased” replacement property, thereby obtaining a dependable stream of rental income and deferring taxation of ...