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Following the 2017 TCJA, new tax laws drastically impacted individuals and corporations. Now, as we approach 2025, many of these changes are set to expire. To stay informed, accountants must monitor any potential extensions and the potential consequences if the Act is allowed to expire. This article discusses expiring provisions and possible extensions of the TCJA. https://lnkd.in/en2PqZkS

In their article with @Bloomberg Tax, my Crowe colleagues Sowmya Varadharajan and Samuel Taieb discuss why it’s imperative for taxpayers to stay up to date with the evolving application of the arm’s-length principle. https://bit.ly/4etWoRj  

Current developments in the taxation of individuals. This semiannual update surveys recent federal tax developments involving individuals, including court cases, rulings, and other guidance. DeHoek & Company, PLLC | 616-456-5530

Deemed Income vs. Real Taxes: Navigating the Dynamics of Modern Taxation In the ever-evolving landscape of taxation, one concept that often puzzles business owners is "Deemed Income." This concept challenges the traditional notion of taxing real income, raising essential questions about fairness and practicality in modern tax systems. Here’s what you need to know:  Understanding Deemed Income: - Legal Assumptions Over Reality: Deemed income refers to income that is taxed based on legal assumptions rather than actual earnings. The law assumes certain transactions or conditions as income, regardless of the real financial outcome. - Purpose of Deeming Provisions: These provisions are often introduced to prevent tax evasion, ensuring that even seemingly innocent transactions don’t slip through the cracks of the tax system. - Judicial Perspective: Courts have upheld the importance of these provisions, even when they inadvertently penalize innocent taxpayers. The intention behind such laws is to safeguard revenue, sometimes at the cost of individual fairness.  Why Deeming Provisions Exist: - Tax Evasion Prevention: Deeming provisions serve as a robust mechanism to counteract complex tax evasion tactics, ensuring that income, whether real or notional, is taxed appropriately. - Addressing Legal Loopholes: These provisions often arise from the need to close loopholes that allow taxpayers to underreport income or avoid taxes altogether. - Corrective Measures: Sometimes, they are implemented to override court verdicts that might have gone against the intended purpose of tax laws.  The Complexities of Deeming Provisions: - Section 50C – A Pain Point: One of the most contentious deeming provisions is Section 50C, where the stamp duty value is deemed as the transaction value for taxing purposes. This can lead to significant hardships, especially when market realities differ sharply from these assessed values. - Legal and Factual Fiction: Deeming provisions can create legal or factual fiction, overriding other sections of the tax act. For example, Section 69C considers unexplained expenses as income, regardless of their true nature. Conclusion: The dynamics of modern taxation, particularly the concept of deemed income, highlight the intricate balance between preventing tax evasion and ensuring fairness to taxpayers. As these provisions continue to evolve, staying informed and seeking expert guidance is crucial for business owners to navigate the complexities of today’s tax environment. Regards R K Murarka  #DeemedIncome #Taxation #BusinessOwners #ModernTaxation #TaxCompliance #IncomeTax #TaxLaw #CA #BusinessStrategy #TaxEvasionPrevention#icai

"Certain provisions are inconsistent with the CNIT statute and case law, and the proposed regulations need to provide additional guidance in certain other areas." VP of Government Relations, Peter N. Calcara, CAE, connected with Pennsylvania Business Report about the upcoming June 24 deadline for comments on a proposed tax regulation from the Pennsylvania Department of Revenue. He shares the PICPA’s perspective around the regulation that has sparked debate around combined reporting for corporate net income tax (CNIT). Read the full article here: https://loom.ly/YzOnWs4

🌟 Supreme Court Decision: Key Insights for Wealth Taxation 🌟 The U.S. Supreme Court's decision from yesterday to uphold the constitutionality of the transition tax is a landmark moment for potential wealth taxation. This ruling provides insight on the definition income realization and its taxability. 🔍 Key Takeaways: Income Realization: The ruling underscores the necessity for strategic planning around income realization to mitigate tax liabilities. Tax Compliance: Staying compliant with evolving tax laws is essential to avoid penalties and ensure optimal financial health. Wealth Management: Proactive wealth management strategies (specifically tax optimization) are vital to navigating the complexities introduced by this decision. We recognize the challenges this decision poses for wealth management and tax strategy. Understanding the nuances of income realization and its impact on wealth tax is crucial for effective financial planning. For a deeper understanding of the Supreme Court’s ruling and its implications for wealth tax, read the full article on WealthManagement.com: https://lnkd.in/giGz6bCh At DeJoy & Co., we are dedicated to guiding you and your advisors through these changes, ensuring compliance, and optimizing your wealth management strategies. #WealthTax #IncomeRealization #TaxPlanning #SupremeCourt #DeJoyAndCo #MoorevUS

Check out the latest article published on WealthManagement.com by our Senior Manager of Business Valuation, Anthony Venette, CPA/ABV, MBA where he discusses the U.S. Supreme Court Decision to Uphold Constitutionality of Transition Tax. #IncomeRealization #TaxPlanning #SupremeCourt

Can you apply to the Australian Taxation Office to have your taxable income for returns that you’ve already submitted? Yes – in certain circumstances. In this article, Lawyer Jack Bresnahan provides an overview and discusses a recent case that provides clarity on factors relevant to granting extension of time for work-related texts. Read more: https://lnkd.in/gccunFsy #taxation #workexpenses #taxdeductions #incometax #ColemanGreig #YourFutureComesFirst

I have analyzed the issues relating to taxing gains at death. See https://lnkd.in/ed7GEjHQ. There are a significant number of Internal Revenue Code and regulations needing coordination with an income tax at death but it is doable with advance planning. There is also the potential of just taxing liabilities in excess of tax basis. There is a combined article reprinted with the permission of Tax Analysts at SSRN that discusses the latter issue. See https://lnkd.in/e63hMzn9. The recently finalized consistent basis at death regulations imply, but do not discuss at all, that under current law there is no taxable disposition at death for income tax purposes. And so legislation is needed regardless of which way this turns out. https://lnkd.in/eCmrxUXw

Rebate under Section 87A Extended to Special Rate Income I am pleased to bring attention to a significant legal development that addresses a contentious issue surrounding Section 87A of the Income Tax Act. In the case of Beena Manishbhai Fofaria vs. Assistant Officer, dated November 22, 2024, the Commissioner of Income Tax (Appeals) has decisively ruled that the rebate under Section 87A is applicable even against income taxed at special rates. This judgment is pivotal as it resolves a long-standing dispute regarding the scope and applicability of the rebate under Section 87A, particularly in the context of special rate incomes, such as short-term capital gains (Section 111A) or long-term capital gains (Section 112/112A). Key Highlights of the Judgment: 🔹 It affirms that the intent of Section 87A is to provide tax relief to eligible taxpayers, irrespective of the rate at which income is taxed. 🔹 The judgment provides a precedential reference for taxpayers who may have been denied this rebate on technical grounds. 🔹 It reinforces a taxpayer-friendly interpretation of the law, aligned with the principles of equity and fairness. This decision marks a significant milestone for taxpayers, as it sets a crucial benchmark for both assessment proceedings and appellate reviews. The ruling will undoubtedly guide the resolution of similar disputes and strengthen taxpayers' claims for rightful benefits under the Act. I encourage tax professionals, advisors, and taxpayers to review this judgment in detail and leverage its insights for accurate tax compliance and planning. Your thoughts and perspectives on this matter are welcome—let's discuss its broader implications! #IncomeTax #Taxation #Section87A #LandmarkJudgment #TaxRebate #LegalUpdates