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Tax Blawg

Tax Talk for Tax Pros

Introduction

Welcome to TaxBlawg, a 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.

The Wall Street Journal's Tax Blog gives “tips and advice for filers,” and Paul Caron’s legendary TaxProf Blog is an excellent clearinghouse for academic and policy-oriented news. Yet, tax practitioners still lack 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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Houston Marriott Westchase, 2900 Briarpark Dr., Houston, Texas 77042

Tuesday, May 14, 2019 – From 7:15 to 9:00 A.M. (Breakfast is included)

The Essentials of Investing in Qualified Opportunity Zones

Summary: Presentation on the fundamentals of this new tax vehicle; will discuss opportunity zones, the requirements of qualified opportunity zone funds and qualified opportunity zone businesses, the tax benefits of investing in a qualified opportunity zone funds, and timing.

The Chamberlain Hrdlicka Tax Forum is open to the public. Anyone is welcome to register and attend.

The ...

People are always asking how long the IRS can wait from the time you file your return to conduct an audit of your income and expenses.  The simple, most definitive answer is "it all depends," so let's take a look at the rules.

The time in which the IRS must conduct its audit is governed by what's known as a "statute of limitations."  That statute doesn't begin to run until you actually file a return.  Once you file a return, the IRS has three years from the time the return was filed (or, April 15th of the year in which you file, if it is filed early) to conduct and complete an audit.  That means that the IRS has to select your return for examination, conduct whatever level of audit it is going to perform, and either get an agreement from you to an additional amount of tax or a refund, secure an extension of limitations period from you, or issue you a document known as a "Notice of Deficiency" (indicating what it has determined your correct tax liability to be and giving you ninety days to go the United States Tax Court). 

If it fails to complete one of these actions within three years, in most situations the proverbial “ballgame” is over and it will be too late for the IRS to assert an additional tax liability for that year.  The filing of an amended return does not extend the period in which an audit must take place.  As you might expect, however, there are exceptions.

Categories: Tax Procedure

Hardly a day goes by when some politician or editorial person doesn't suggest that we don’t need the IRS or should simply do away with it.  Most of them come in connection with suggestions for changing the tax system to something like a national retail sales tax.  What these people fail to understand, and this writer is not challenging the sincerity of their views, is that without the IRS, our tax gap would explode geometrically.  We call our system a “voluntary” one, but we remain short of “volunteers”: there are simply too many people and businesses who don’t get around to filing ...

You are invited to join us for the Chamberlain Hrdlicka San Antonio Tax Forum on Tuesday, March 12, 2019 at Club Giraud, 707 N. St. Mary's Street, San Antonio, Texas 78205 from 12:00-1:00 p.m. Lunch is included in the admission price.

Topic: Section 199A - New 20% Deduction on Qualified Business Income 

Summary: What you need to know; How to maximize the deduction; Details on Final Regulations.

Speakers: Katherine Noll and Joshua Sutin

Chamberlain Hrdlicka History:

Chamberlain Hrdlicka started out as a tax-focused law firm in Houston in 1965. While Chamberlain ...

Home Ownership Center, 500 South 15th Street, McAllen, Texas 78501

Monday, March 4, 2019 - From 9:00 a.m. - 1:00 p.m. (Lunch is included)

Workshops:

8:30 - 9:00 a.m. - Registration

9:00 – 10:20 a.m. – Tax Controversy and Tax Reform Update: A Timely Review of The New Partnership Audit Rules,  and Recent Developments in Tax Reform, Including Section 199A and Other Issues.

We will provide a timely review of the new centralized partnership audit procedures and recent developments with the 2017 Tax Cuts and Jobs Act, including details on the final Treasury Regulations on the new ...

Houston Marriott Westchase, 2900 Briarpark Dr., Houston, TX 77042

Tuesday, February 26, 2019 – From 7:15 to 9:00 A.M. (Breakfast is included)

Topic: 2018 Tax Return Preparation Issues – Understanding How the 2017 Tax Cuts and Jobs Act Affects 2018 Returns

This month’s Forum will be substantially limited to how the Section 199A deduction for qualified business income filters through to the 2018 tax returns.  We will also discuss recent regulatory developments, including final Section 199A regulations.

Speakers

Chamberlain ...

Houstonian Hotel - 111 North Post Oak Lane

Thursday, February 21, 2019 – From 7:15 to 9:00 A.M. (Breakfast is included)

Topic: 2018 Tax Return Preparation Issues – Understanding How the 2017 Tax Cuts and Jobs Act Affects 2018 Returns

This month’s Forum will be substantially limited to how the Section 199A deduction for qualified business income filters through to the 2018 tax returns.  We will also discuss recent regulatory developments, including final Section 199A regulations.

Speakers

Chamberlain Hrdlicka History:

As if the waters for small captive insurance arrangements hadn’t been muddied enough after Avrahami v. Commissioner, on June 18, 2018, the U.S. Tax Court issued the second opinion in a small captive case, Reserve Mechanical Corp. v. Commissioner, this time holding that the taxpayer’s participation in a risk pool failed to satisfy the risk distribution requirement (i.e., the sharing of a sufficient number of independent insurance risks so that no one claim can have too great an adverse financial effect on the insurer) to establish a bona fide insurance arrangement. Until this ...

For my fellow procrastinators whose federal tax returns are on extension, with the October 15th deadline rapidly approaching, perhaps the burning question has crossed your mind, “If I file electronically while the government is shut down, will my return be accepted?”  Yes, I can happily report that a return electronically submitted to the IRS at 3:43 p.m. this day was “accepted for filing” at 4:04 p.m., efficiency approaching a Michael Phelps-like performance. Perhaps the IRS has designed a system that operates better when it is staffed only by computers rather than by ...

The Quality Stores employment tax refund case was argued before the Supreme Court on January 14, 2014.  An explanation about the issue at stake can be found in prior Taxblawg.net postings.  Although the outcome of the case remains in doubt, the possibility of a taxpayer victory means that employers should start thinking about the need to satisfy an important prerequisite to qualify their claims for refund.

Employment (FICA) taxes have both an employer and an employee component. A taxpayer victory in Quality Stores will enable both employers and terminated employees to recover their ...