AICPA’s Comments on Notice 2011-66

On September 7, the AICPA Carryover Basis Task Force sent comments to the IRS on Notice 2011-66 making suggestions and requesting additional guidance on several issues, some of which are summarized below. They suggest a “policy of restraint” in auditing taxpayers having carryover basis issues for tax years after 3 years from the filing of the…

Read More

Form 8939 Filing Deadline Extended

Today, pursuant to Notice 2011-76 (the “Notice”), the IRS extended the due date for filing the Form 8939 from November 15, 2011 to January 17, 2012.  This Notice is unexpected considering shortly ago on August 29, 2011 the IRS issued Notice 2011-66 extending the deadline for filing the Form 8939 to November  15, 2011.  Rev. Proc. 2011-41 was…

Read More

Fed Up with the QTIP Trust? Tax Results of Terminating QTIP Trust

Many of today’s modern estate plans employ a marital trust under Code sections 2056(b)(7) or 2523(f) known as a QTIP trust (QTIP stands for Qualified Terminable Interest Property).  This is a trust which grants a life income interest to spouse and upon his or her death, named beneficiaries receive the remainder.  The property funding the…

Read More

Property Rights: Florida May Refuse To Pay Its Bills

After more than 10 years of eminent domain litigation, two jury trials and a number of appeals, thousands of South Florida homeowners were recently awarded constitutional compensation for the destruction of their private property by the State of Florida. In the mid-2000’s, the State destroyed tens of thousands of healthy citrus trees as part of…

Read More

IRS Extends Offshore Reporting Deadline

Due to Hurricane Irene, the IRS extended the deadline for participating in the Offshore Voluntary Disclosure Initiative (OVDI) from August 31, 2011 to September 9, 2011.  The new deadline applies both to submissions into the program and requests for a 90 day extension. For details on the OVDI program, please see our previous posts located…

Read More