Lee B

This a big gray area that has a lot of nuanced interpretation depending on the facts and circumstances which will need some detailed research.

The relief will apply to Forms in the 1040, 1120 and 1099 series. "The relief applies to the failure to file penalty. The penalty is typically assessed at a rate of 5% per month and up to 25% of the unpaid tax when a federal income tax return is filed late. This relief applies to forms in both the Form 1040 and 1120 series, as well as others listed in Notice 2022-36, posted today on IRS.gov. To qualify for this relief, any eligible income tax return must be filed on or before Sept. 30, 2022." "Relief is automatic; most of $1.2 billion in refunds delivered to eligible taxpayers by next month Penalty relief is automatic. This means that eligible taxpayers need not apply for it. If already assessed, penalties will be abated. If already paid, the taxpayer will receive a credit or refund. As a result, nearly 1.6 million taxpayers who already paid the penalty are receiving refunds totaling more than $1.2 billion. Most eligible taxpayers will receive their refunds by the end of September." https://www.irs.gov/pub/irs-drop/n-22-36.pdf I must say that this is unexpected!

It would be hard to work somewhere you are getting constantly bombarded with anger and threats.

"Software capitalization rules for external-use software The capitalization rules for external-use software differ from those involving internal-use software and can be more strict. External-use software refers to tools that a company plans to sell, lease or market to external users. Here are the stages of this process: Preliminary stage: During the preliminary stage and before the software is technologically feasible, companies expense costs as incurred. This stage involves activities to understand the goals for the product's features, like research, initial project planning, prototyping and design work. Technologically feasible stage: Technological feasibility of a software product occurs when the organization has completed all planning, designing, coding and testing activities and a design or working model is ready for customer testing. Costs involve coding, testing and labor costs, and companies can capitalize on these expenses. Available for sale stage: Once a software product meets technical performance requirements and is available for sale and release to customers, a company starts recording expenses as incurred. The remaining costs involve maintenance and support, error correction, troubleshooting and discovery." These are GAAP not Tax Guidelines

"The court ruled that the U.S. District Court for the District of New Hampshire was wrong to dismiss the court challenge based on an alleged lack of jurisdiction." This is nothing more than a narrow procedural ruling.

"7. Can I change from one method to another in calculating substantially equal periodic payments? Yes. Rev. Rul. 2002-62 permits a one-time change from either the amortization method or the annuitization method to the required minimum distribution method." The key phrase here is a "one time change" See Revenue Rule 2002 - 62 FAQs He would have to do this with the knowledge and assistance of his fiduciary. If not done correctly, the penalty is calculated on the entire amount taken.

When money is involved all of the ghosts and gremlins come out of the woodwork.

Online search says the iphone 6 is no longer supported.

Updates are usually phased in over several days. It's not possible to do them all at once.

SAN FRANCISCO — "Apple disclosed serious security vulnerabilities for iPhones, iPads and Macs that could potentially allow attackers to take complete control of these devices. Apple released two security reports about the issue on Wednesday, although they didn't receive wide attention outside of tech publications. Apple's explanation of the vulnerability means a hacker could get "full admin access" to the device. That would allow intruders to impersonate the device's owner and subsequently run any software in their name, said Rachel Tobac, CEO of SocialProof Security. Ransomware attacks are hitting small businesses. These are experts' top defense tips Security experts have advised users to update affected devices — the iPhone6S and later models; several models of the iPad, including the 5th generation and later, all iPad Pro models and the iPad Air 2; and Mac computers running MacOS Monterey. The flaw also affects some iPod models. Apple did not say in the reports how, where or by whom the vulnerabilities were discovered. In all cases, it cited an anonymous researcher."

My understanding of this situation is that you need to advise your client of the Filing Requirements, Potential Penalties and etc. Ultimately, it's your client decision after you are sure that they understand.

Copied from Page 10 of Pub17: "Nonresidents with rental property in Oregon You don’t have to file an Oregon return if: • Your only Oregon-source income is from rental property, and • You have a loss from the rental activity for the year. However, you must file Oregon returns for all applicable loss years if: — You later sell the rental property in a fully-taxable transaction; — The sale results in gain that would otherwise be taxed by Oregon; — You have suspended passive activity losses from the rental activity; and — You are deducting your suspended losses from that gain on your federal return."

Copied from Accounting Today: "Key effects on business in the bill that passed the House include: A 15% minimum tax on corporations with over $1 billion in revenue, with exceptions made for accelerated depreciation and for subsidiaries of private equity starting in 2023, to raise $222 billion; A 1% excise tax on stock buybacks, effective Jan. 1, to raise $74 billion; An $80 billion boost to the Internal Revenue Service budget to hire more agents, upgrade technology in order to boost revenue collection; An extension of loan loss limitation tax breaks from the Trump tax package; New Superfund taxes on oil companies; Drug prices negotiated by Medicare for the first time, with a tax penalty imposed on drug companies failing to abide by new prices; price negotiations begin in 2026 with 10 high-priced drugs; penalties imposed for price increases in sales to Medicare; A $2,000 per year cap on out-of-pocket costs for seniors enrolled in a Medicare drug plan; Approximately $374 billion in energy and climate-related provisions including tax incentives for green energy projects, a $7,500 tax credit for purchasing new electric vehicles and $4,000 credit for used EVs. Limits imposed on supply chain sourcing for EVs that qualify; and A three-year extension of subsidies for Obamacare premiums, preventing expiration of subsidies in 2023."

This is the definition of "irony" since these are our elected representatives who created the situation! Here we go lurching from one crisis to the next, with no evidence of long term planning or thinking! "U.S. lawmakers are pressing the IRS to explain how it plans to relieve a backlog of tax returns that have delayed refunds and to detail what measures it's taking to improve customer service. Dozens of congressional Republicans and Democrats made the demands in a letter to the Internal Revenue Service, obtained by Bloomberg News. The IRS has said it plans to reduce by year-end the backlog of paper filings, which have been running at historically high levels since the pandemic hit. But the lawmakers, citing data from an IRS watchdog, said that the backlog has grown and that the agency has failed to meet targets to hire new employees. Internal Revenue Service headquarters in Washington, D.C." "The IRS must take additional steps to improve customer service issues, decrease processing delays, and work down the backlog of paper returns and correspondence by continuing the maximum use of overtime and surge teams," according to the letter, signed by 93 House and Senate lawmakers. The group also called for "the continued suspension of automated notices and collections — which have been critical in reducing pandemic-related tax return and correspondence backlogs." The group is led by Senator Bob Menendez of New Jersey and Representative Abigail Spanberger of Virginia on the Democratic side and Senator Bill Cassidy of Louisiana and Representative Brian Fitzpatrick of Pennsylvania on the GOP side. The lawmakers asked IRS Commissioner Chuck Rettig to answer questions this week about how the agency plans to resolve the backlog and bring on additional workers."

It appears that the key question is, "What is NY's legal definition of which transactions are subject to the RETT?

Is the easement permanent ?

I am getting a headache just reading your post. I hope everyone is still talking to each other after this is wrapped up.

My experience with trusts is that most clients just view it "legal stuff" and just do what they would have done if there was no trust.

https://www.taxconnections.com/taxQuestions/Can-I-please-get-clarification-on-the-revisions-to-Form-5471/349

Not reducing QBI by the 1/2 SE Tax would be a classic case of "double dipping."

Christian, If it was my client, I would file 2021 with the 50% penalty. Then file 2022 with the combined 2021 & 2022 RMD, which will match the 2022 1099 R. I would still try for the waiver, assuming you can assemble enough supporting documentation without the Doctors Letter, the worst they can do is say no!

AICPA demands IRS pick up the phone faster for tax pros "The American Institute of CPAs wants the Internal Revenue Service to pick up the phone faster on its so-called Practitioner Priority Service for tax professionals and make other fixes, pointing to a "plummeting" level of service in recent years. Taxpayers and tax pros alike have long complained about the difficulty of reaching the IRS over the phone and those complaints have mounted during the COVID-19 pandemic. Despite recent efforts by the IRS to ease the burden that the backlog has caused for taxpayers and practitioners, the AICPA notes that service levels for the practitioner priority service phone line had been in continuous decline for several years. The National Taxpayer Advocate's annual report to Congress found that the percentage of calls answered on the PPS line declined from 78.3% in fiscal year 2019 to 28.0% in FY 2021, with the average speed of answering the phone nearly doubling from 8.8 minutes to 16.1 minutes over that same period. Still, that was better than the level of service for regular taxpayers, where the percentage of calls answered by IRS employees declined from 28.7% in FY 2019 to 11.4% in FY 2021 and the average speed of answer went from 16.2 minutes in FY 2019 to 22.8 minutes in FY 2021. Many taxpayers have complained they were unable to get through at all. "We are hearing from tax practitioners everyday regarding their significant PPS line challenges and the impact those challenges have on their interactions with IRS on behalf of taxpayers," said the AICPA letter."

The correct way to do this is "unreimbursed partnership expenses" deducted of Page 2 of Schedule E, assuming that that the required language is present in the Partnership Operating Agreement.

My understanding is that he must withdraw the amount of the missed 2021 RMD plus the the 2022 RMD.

Tracy, The biggest potential taxable income offset would be available only by starting a Schedule C Sole Prop business. In your son's situation the focus needs to be on preserving as much of his Settlement proceeds, net of legal fees as possible. Given your original post, I am not aware of any significant tax offsets.