1. Practitioners See Need for Guidance on Controlled Group Rules
    • Provisions of the controlled group rules have been working their way beyond qualified plans, making the code section ripe for guidance, according to some tax professionals. [Tax Notes Today, 11/4/2021, article by Caitlin Mullaney]
  1. Fifth Circuit Affirms Couple’s Liability for Gift Taxes
    • The Fifth Circuit affirmed a Tax Court decision that held a couple liable for gift tax deficiencies stemming from limited partner interests the wife transferred to a family trust, finding that the Tax Court properly determined that the interests were percentage interests rather than fixed dollar amounts based on clear and unambiguous language in the transfer documents. [Mary P. Nelson et al.;  CA5, No. 20-61068, 11/3/2021]
  1. IRS Issues Practice Unit on Calculating FTC Limitation
    • The IRS has issued a practice unit providing an overview of the rules for the allocation and apportionment of expenses, losses, and other deductions of a taxpayer in calculating the foreign tax credit limitation. (26 slides) [ INT-C-051; revised 9/30/2021, rel. 11/2/2021]
  1. IRS Looking Into Phone-Line-Jumping Service
    • The IRS is reviewing complaints that a private company’s service of selling slots at the front of the hold queue for the agency’s clogged phone lines is making it tougher for others to get their calls answered. [Tax Notes Today, 11/5/2021, article by Kristen Parillo]
  1. IRS Announces Pension Plan Limits for 2022
    • The IRS has announced (IR-2021-216) the cost of living adjustments (Notice 2021-61) that affect dollar limitations for pension plans and other retirement-related items for the 2022 tax year, noting an increase in the income ranges for determining eligibility to make deductible contributions to IRAs, to contribute to Roth IRAs, and to claim the saver’s credit. [IR-2021-216, 11/4/2021]   [Notice 2021-61; 2021-47 IRB 1, 11/4/2021]

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 I have relied on Tax Analysts® to provide reliable and timely analysis of Federal tax developments for over 30 years. The “headnotes” you see here are from “Tax Notes Today” In my opinion, the preeminent source of accurate information and thoughtful analysis of important developments and trends in Federal taxation.

(*** identifies item with useful analysis of current issue but not covered in Lynn’s recorded commentary due to complexity and time required for fair comment.)