THE IRS TARGETS MIDDLE-MARKET COMPANIES; WHAT THEY NEED TO KNOW

Because of the IRS’ new responsibility to enforce the employer mandated health care provisions of the ”Affordable Care Act” and other issues,  it appears the IRS is going to start targeting  Middle Market companies for audit.   

The audits will be performed by the Large Business International Division (LB&I Division) which is responsible for audits of the Fortune 1000 companies.  However the LB&I Division is also responsible for audits of companies with assets of $10 million to $100 million which is the typical size of companies considered to be midsized.  Because of limited resources and the historical focus on the Fortune 1000 there has been lighter coverage of middle-market in the past.  But no more, attention, resources and expertise are being shifted to the middle-market sector. This means more middle-market companies will be audited.

Normally middle-market companies do not have the same resources as the Fortune 1000 and are not as aware of IRS audit procedure or their rights as a taxpayer.   Many have an outside CPA that prepare the tax return and advise the owner or officers of tax and accounting issues.  However they will be faced with seasoned IRS auditors who are used to have immediate access to records and the tax professional during the audit.  This can cause significant issues during the audit for the owner and officer of the middle-market company.  Thus the middle-market company, as with all taxpayers, should assess their resources to see what is need to be prepared and which audit defense resources can be utilized.

The time to prepare for an audit is not when you get the audit notice, but when your tax return is prepared.   So if you have not thought of the possibility of being audited, this is a good time to have a conversation to see what needs to be done.  Normally, if a company is prepared for an audit before they receive the audit notice, an audit should never be a problem.

RESPONSABILITIES OF RUNNING A BUSINESS

As a small business owner, you can have the ability of creating something for yourself rather than for someone else.  You also have a unique lifestyle; more freedom and flexibility than that of an employee. However, you also have greater responsibilities. As a business owner you might retain the services of professionals such as accountants, attorneys and human resources professionals.  However at the end of the day, you are the one responsible to understand the basics.  For example giving your bookkeeper full range of responsibility of overseeing your financial records without accountability or taking their representations at face value without asking questions is not being a responsible business owner.  You should question and challenge the advice provided by attorneys, CPAs and other professionals.  This is one way to evaluate the effectiveness of your professional.  If they have problems with being questioned, then get a new professional.  This might cost you in higher fees, but at the end of the day, you will be rewarded in being assured in having top notch professionals on your team.

Another mistake some business owners make is giving total administrative control over the other partner.  It is good to have one partner to be given the task of a CEO, also known as a tax partner.  However that person should give monthly reports to the other partners, including financial statements.  This might be tough if the other partner(s) are friends or family, but you are involved in a business which is your livelihood.  Business MUST be separate from personal relationships.  This might be easier said than done, but doing so will not only protect your business but also your personal relationships. In some cases it is best to never do business with friends and family

If you are intimidated in tax and accounting concepts you might want to take some good seminars provided by Small Business Development Centers, sponsored by U.S. Small Business Administration [SBA].  These seminars are a great way to get grounded without trying to be an accountant.  They can be found on the web at

http://www.sba.gov/content/small-business-development-centers-sbdcs

Another resource might be the local city college.  But in any event, remember it is your business and at the end of the day you are the only person responsible for its success.

Are You Required to File 1099s?

If you use independent contractors to perform services for your business and you pay them $600 or more for the year, you are required to issue them a Form 1099-MISC after the end of the year to avoid facing the loss of the deduction for their labor and expenses. The 1099s for 2012 must be provided to the independent contractor no later than January 31 of 2013.

It is not uncommon to, say, have a repairman out early in the year, pay him less than $600, and then use his services again later and have the total for the year exceed the $600 limit. As a result, you overlook getting the information needed to file the 1099s for the year. Therefore, it is good practice to have individuals who are not incorporated complete and sign the IRS Form W-9 the first time you use their services. Having a properly completed and signed Form W-9s for all independent contractors and service providers eliminates any oversights and protects you against IRS penalties and conflicts.

IRS Form W-9 is provided by the government as a means for you to obtain the data required to file the 1099s for your vendors. It also provides you with verification that you complied with the law should the vendor provide you with incorrect information. We highly recommend that you have a potential vendor complete the Form W-9 prior to engaging in business with them. The form can either be printed out or filled onscreen and then printed out. A Spanish-language version is also available. The W-9 is for your use only and is not submitted to the IRS.

To avoid a penalty, copies of the 1099s must to be sent to the IRS by February 28, 2013. They must be submitted on magnetic media or on optically scannable forms.

This firm provides 1099 preparation services. If you need assistance or have questions, please give this office a call.

Will Capital Gains Be Changed?

Currently, capital gains rates for the sale of assets held over one year are taxed at 15% (0% to the extent a taxpayer is in the 15% or lower regular tax bracket), compared with a top tax of 35% for ordinary income. Without Congressional action, these rates will increase to 20% (18% for assets held over 5 years) in 2013.

Although there has been some discussion related to extending the 15% rates for another year (2013), to date, Congress has not provided any indication one way or the other. Even without providing guidance for 2013, the House Ways and Means Committee and the Senate Finance Committee are already holding joint meetings to discuss capital gain reform.

Capital gains and related issues make up approximately half of the tax code, in excess of 20,000 pages. In addition, those with the most capital gains are generally the wealthier taxpayers, and lower capital gains rates contribute to the disparity in tax rates between the wealthy and the average working family that we hear so much about in the media. As an example, Billionaire Warren Buffet announced that his tax rate was 14%, which is lower than the rate paid by his secretary.

Some contend that capital gains should be taxed as ordinary income and should even be taxed as the income is earned rather than when the gain is realized.

Still others maintain that doing away with special long-term capital gains rates would discourage investment and would further harm the economy.

It is difficult to predict what lies ahead. But you can count on this firm to stay on top of this issue and to keep you abreast of the ever-changing tax landscape.

CONGRESS LEAVES US HANGING AGAIN ON THE AMT

Here it is, almost the end of the year, and as they have done for several years, Congress has not indicated if they will extend the higher AMT exemption amounts or allow them to revert to lower amounts that were in effect before exemptions were increased to shield the middle class from the punitive tax. A recent Congressional report indicates that, if Congress does not extend the AMT break, one in five taxpayers will be impacted by the AMT in 2012.

Originally conceived to combat taxpayers in the higher-income brackets who utilized legal tax shelters and tax preferences to avoid paying income tax, the AMT can be tricky and hit you when least expected. The tax was supposed to inflict a “minimum” tax on those who were able to avoid the regular tax. However, years of inflation have pushed many middle-income taxpayers into the reach of the AMT. Although there is a long list of items that can trigger the AMT, for most individuals, the triggers include the following or a combination of the items listed below:

·      Preference income from exercising stock options from an employer's qualified plan, sometimes referred to as incentive stock options (ISOs);

·      Having large itemized tax deductions;

·      Having large miscellaneous itemized deductions;

·      Large itemized deductions for state income or sales tax, real property tax and personal property tax;

·      Large medical itemized tax deductions;

·      Home equity debt interest deduction; and

·      Interest income from private activity bonds.

Because of its unintended impact on the middle class, Congress has been promising AMT reform. In the meantime, annually increasing the amount of income exempted from AMT has been their temporary fix, and what that amount will be for 2012 is what Congress has yet to decide. Complicating the issue is that the AMT as it is currently structured provides a significant amount of tax revenue that Congress is reluctant to concede without a replacement. Most analysts have been predicting the higher exemptions will be extended for 2012, and possibly into 2013. But you never know, and we will have to wait and see.

There are planning techniques that can be used to avoid or mitigate the effects of the AMT. If you anticipate an AMT problem this year, it may be appropriate for you to make an appointment to see if there are any steps that can be taken to alleviate the effects of the AMT in your specific tax situation.

JULY 2010 TAX BRIEFING

Addresses for Filing Elections and Statements:
Following the reorganization of the IRS (as required by the IRS Restructuring and Reform Act of 1998), the IRS issued Notice 2003-19 (2003-1 CB 703) to advise taxpayers of the revised addresses for filing elections, statements, returns, and other documents with the IRS. Since then, many of the locations listed in Notice 2003-19 for filing documents have changed and are no longer accurate. Accordingly, the IRS has revoked Notice 2003-19 . Instead, the address for filing many of the documents listed in Notice 2003-19 can be found (1) on www.irs.gov ; (2) in current IRS forms, instructions to forms, and publications; or (3) on a new IRS webpage accessible at www.irs.gov/file/article/0,,id=224931,00.html.

Bankruptcy Trustees Requesting Tax Refunds:
The IRS provided guidance to the trustee (or debtor- in-possession) representing a bankruptcy estate for properly requesting a tax refund, other than an application for a tentative carryback or refund adjustment under IRC Sec. 6411 . [ Editor's Note: The debtor in a Chapter 11 reorganization is a debtor-in-possession when the debtor remains in full control of all of the assets.] This guidance supersedes Rev. Proc. 81-18 (1981-1 CB 688) and applies to all cases commenced under the Bankruptcy Code except for Chapter 9 municipal debt adjustment cases and Chapter 15 ancillary and cross-border cases. Rev. Proc. 2010-27, 2010-31 IRB.

Gulf Oil Spill Assistance Day:
The IRS listed the Taxpayer Assistance Centers in seven Gulf Coast cities that will be open this Saturday, 7/17/10, to provide face-to-face assistance for taxpayers impacted by the BP oil spill. The following locations will be open from 9 a.m. to 2 p.m. Central Time: (1) 1110 Montlimar Drive, Mobile, Ala.; (2) 651-F West 14th St., Panama City, Fla.; (3) 7180 9th Ave. North, Pensacola, Fla.; (4) 2600 Citiplace Centre, Baton Rouge, La.; (5) 423 Lafayette St., Houma, La.; (6) 1555 Poydras Street, New Orleans, La.; and (7) 11309 Old Highway 49, Gulfport, Miss. Individuals with questions about the tax treatment of BP payments or who are experiencing filing or payment hardships because of the oil spill will be able to work directly with IRS personnel. News Release IR-2010-85.

Preventive Health Services:
Temporary regulations (found in TD 9493 ), issued in conjunction with regulations issued by other federal agencies, address preventive health services under the Patient Protection and Affordable Care Act. Group health plans and health insurance issuers offering group health insurance must provide coverage for, and may not impose any cost-sharing requirements (such as a copayment, coinsurance, or deductible) for, the enumerated list of items or services, which includes "immunizations for routine use in children, adolescents, and adults that have in effect a recommendation from the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention with respect to the individual involved." Temp. Reg. 54.9815-2713T generally applies to plan years beginning on or after 9/23/10; however, see Temp. Reg. 54.9815-1251T for the application of these rules to grandfathered health plans.

Copyright © 2010 Thomson Reuters/PPC. All rights reserved.

THE TAX COURT DISALLOWS THE EXCLUSION OF THE SALE OF HOME

In a tax court decision [David A. Gates and Christine A Gates, Petitioners v. Commissioner of the IRS, Respondent], held that taxpayers, who voluntarily demolished and constructed a new house on their property in order to enlarge and remodel their home, couldn't exclude the gain on the sale of the new house under the Code Sec. 121 exclusion for the sale of a principal residence. Although the taxpayers owned and used their old house as a principal residence for at least two of the five years before the sale, the Code Sec. 121 exclusion did not apply because they never lived in the new house and it was never used as their principal residence.

The Code Sec. 121 exclusion allows a taxpayer to exclude from income up to $250,000 of gain from the sale of a home owned and used by the taxpayer as a principal residence for at least two of the five years before the sale. The full exclusion does not apply if, within the two-year period ending on the sale date, the exclusion applied to another home sale by the taxpayer. Married taxpayers filing jointly for the year of sale may exclude up to $500,000 of home sale gain if (1) either spouse owned the home for at least two of the five years before the sale, (2) both spouses used the home as a principal residence for at least two of the five years before the sale, and (3) neither spouse is ineligible for the full exclusion because of the once-every-two-year limit.

If you want more information or need assistance, please call our office

JUNE 2010 TAX BRIEFING

First-time Homebuyer Credit:
The Treasury Inspector General for Tax Administration (TIGTA) released a report on the IRS's efforts to identify and prevent fraudulent Section 36 First-Time Homebuyer Credits claimed on 2008 Form 1040's and 1040X's—for the full report, go to www.treas.gov/tigta/auditreports/2010reports/201041069fr.pdf . TIGTA found that 10,282 taxpayers received credits for homes used by other taxpayers to claim the credit (in one case, 67 taxpayers used the same home), while $9.1 million went to 1,295 prisoners who were incarcerated when they reportedly purchased their home (including 241 prisoners serving life sentences). While admitting there were questionable claims, the IRS responded that it blocked or denied nearly 400,000 questionable credit claims, saving taxpayers more than $1 billion.

Zero Rate Interest Netting:
There is a net interest rate of zero under IRC Sec. 6621(d) for the period of time that interest is payable and allowable on equivalent underpayments and overpayments of tax by the same taxpayer. To qualify, interest must be payable under Subchapter A of Chapter 67 of the Code (interest on underpayments) and allowable under Subchapter B of Chapter 67 of the Code (interest on overpayments) by the same taxpayer. An IRS legal memo concluded that interest on an underpayment of tax paid through a Chapter 11 bankruptcy plan could not be netted against allowable overpayment interest because the interest paid through the Chapter 11 plan is not interest payable under the Internal Revenue Code, as required by IRC Sec. 6621(d) . ILM 201024040 .

Health Care Reform:
An extensive set of regulations (found in TD 9491 ) implement Public Health Service Act (PHS Act) sections 2704 (preexisting condition exclusions), 2711 (lifetime and annual dollar limits on benefits), 2712 (rescissions), and 2719A (patient protections). PHS Act section 2704 generally is effective for plan years (in the individual market, policy years) beginning on or after 1/1/14 (on or after 9/23/10 for enrollees, including applicants for enrollment, who are under 19 years of age), while the rest of the provisions generally are effective for plan years (or policy years) beginning on or after 9/23/10. The regulations are part of a multiphase rule project affecting healthcare insurance plans, and were issued in conjunction with regulations issued by the Departments of Labor, and Health and Human Services. [ Editor's Note: PPC's Guide to Health Care Reform (HCR) , which will be available by 9/1/10 and updated quarterly, will have detailed coverage of these and other health care reform provisions.]

Copyright © 2010 Thomson Reuters/PPC. All rights reserved.

GETTING THE RIGHT AMOUNT OF TAX WITHELD

In most situations, the tax withheld from your pay will be close to the tax you figure on your return - if you follow these two rules.
• You accurately complete all the Form W-4 worksheets that apply to you.
• You give your employer a new Form W-4 when changes occur.

However, because the worksheets and withholding methods do not account for all possible situations, you may not be getting the right amount withheld. This is most likely to happen in the following situations:
• You are married and both you and your spouse work.
• You have more than one job at a time.
• You have nonwage income, such as interest, dividends, alimony, unemployment compensation, or self-employment income.
• You will owe additional amounts with your return, such as self-employment tax.
• Your withholding is based on obsolete Form W-4 information for a substantial part of the year.
• Your earnings are more than $130,000 if you are single or $180,000 if you are married.
• You work only part of the year.
• You change the number of your withholding allowances during the year.

If you need help downloading Form W-4 or have questions on how to fill it out properly, give us a call. We are happy to help.

IRS IS NOT COMPLYING WITH LEGAL REQUIREMENTS FOR SEIZURES OF ASSETS

The IRS Taxpayer Inspector General for Tax Administration recently issued a report on IRS seizures that included instances of IRS still failing to meet all legal requirements in seizures. They reviewed a random sample of 50 of the 578 seizures conducted from July 1, 2008, through June 30, 2009, looking at the required 58 guidelines for each seizure. They identified 34% of the seizures in which the IRS did not comply with the Internal Revenue Code.

If you wish to review the entire report click on the following link: http://www.treas.gov/tigta/auditreports/2010reports/201030049fr.pdf

COURT SUPPORTS IRS AGAINST “S” CORPORATION FOR UNDERPAYING EMPLOYEE-OWNER

Background
A “S” Corporation if a regular corporation that is treated like a sole proprietorship or partnership for tax purposes resulting in the net income of the corporation flowing through the individual tax returns and taxed at the lower individual tax rate in lieu of the corporate rate. Unlike an unincorporated self-employed person, that income is not subject to self-employment taxes. Consequently, the tax code requires employee – owners of “S” Corporations to be paid a “reasonable” salary thus requiring the withholding and payment of Social Security, Disability and Unemployment taxes. The salary is treated as a corporation expense, reducing the amount of income that flows through the sole proprietor or partner.

In times past, a common practice was to pay a minimal salary to the employee-owner and take out cash as a dividend. This will reduce total taxes by reducing the amount paid in Social Security, Disability and Unemployment taxes. For example, the employee-owner would take a $24,000 salary per year and withdraw cash from the corporation of $100,000 as a dividend. The Social Security, Disability and Unemployment tax would be paid on the $24,000 but not on the $100,000.

Court Ruling
In Watson v. U.S the district court ruled that a portion of the dividend distributions by an “S” corporation to its sole owner should be recharacterized as wages subject to employment taxes, the court rejected the corporation's assertion that IRS could not compel the corporation to pay a higher salary to the owner. This resulted in underreporting and underpayment penalties and interest on the corporation’s payroll tax returns over a two-year period.

Conclusion
Employee-owners of “S” corporations should pay a “reasonable” salary. What is a “reasonable” salary? That is a good question; there is no guidance in tax law or by the IRS. It is a case-by-case determination. To determine a reasonable salary, one needs to look at the prevailing wages paid for the same job description of the employee-owner and the income of the corporation.

Please call me for guidance on how this affects you personally.

CALIFORNIA ADOPTS PERMANENT REGULATIONS FOR FILM CREDIT

Effective May 19, 2010 the California Film Commission (CFC) adopted eight final regulations that implement the Film and Television Tax Credit Program; which was previously adopted as an emergency regulation. The final regulations specify the process for the tax credit application and certificate issuance process, the application's contents, and the kind of production and wage expenditure that qualify. The CFC has issued a release summarizing the more significant changes in the regulations, including the following requirements:

(1) All productions' Financing Sources Report must be accompanied by documentation confirming at least 60% of the production's financing
(2) A new TV series for basic cable must have a running time of no less than 60 minutes
(3) A miniseries must consist of two or more episodes with a total running time of at least 150 program minutes.

Please call our office if you want more information or need assistance

IMPORTANT INFORMATION FOR CALIFORNIA REGISTERD DOMESTIC PARTNERS

On February 24, 2006 the IRS issued a determination that an individual who is a Registered Domestic Partner (RDP) in California must report all of his or her income earned from the performance of personal services. However, California law changed on January 1, 2007 to treat the earned income of an RDP as community property for property law and state income tax purposes. Consequently, a California RDP must report one-half of the community income, whether received as compensation for personal services or income from property, on his or her federal income tax return. Similarly, an RDP is entitled to one-half of the income tax withheld on the income. Finally, the requirement under California law to treat an RDP's earnings as community property and thus one-half vested in the partner, does not result in a transfer of property to the partner for federal gift tax purposes.

For tax returns for 2009 and before a Registered Domestic Partner can amend prior returns to report his or her income in this manner.

Consequently, a Registered Domestic Partner in California who prepares an Offer in Compromise must include the assets of the other partner in figuring the Taxpayer's ability to pay their income taxes even if they file separate. This is because California law provides that both domestic partners have an equal interest and liability in the community property.

HIRE ACT PAYROLL TAX EXEMPTION

Following changes by the HIRE Act signed by President Obama on 3/18/10, employers hiring unemployed workers after 2/3/10 and before 1/1/11 may qualify for a 6.2% payroll tax incentive, in effect exempting them from their share of the Social Security tax on wages paid to these workers after 3/18/10. A revised Form 941 (Employer's Quarterly Federal Tax Return) and instructions, to be used in claiming the exemption beginning with the second calendar quarter of 2010, are now available for download on www.irs.gov . The IRS also updated its series of Frequently Asked Questions (FAQs) on the HIRE Act payroll tax exemption—click on www.irs.gov/businesses/small/article/0,,id=220750,00.html
News Release IR-2010-64.

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TAX INCENTIVES FOR SMALL BUSINESS - RECENT LIGISLATION

A variety of business tax deductions and credits were created, extended and expanded by the American Recovery and Reinvestment Act of 2009 (ARRA), this year's Hiring Incentives to Restore Employment (HIRE) Act and the Affordable Care Act. Because some of these changes are only available this year, eligible businesses only have a few months to take action and save on their taxes. Here is a rundown of some of the key provisions.

New Health Care Tax Credit Helps Small Employers
The small business health care tax credit, created under the Affordable Care Act, is designed to encourage small employers to offer health insurance coverage for the first time or maintain coverage they already have.
The credit takes effect this year and is generally available to small employers that pay at least half the cost of single coverage for their employees in 2010. The credit is specifically targeted to help small employers that primarily employ low- and moderate-income workers.

For tax years 2010 to 2013, the maximum credit is 35 percent of premiums paid by eligible small business employers. The maximum credit goes to smaller employers - those with 10 or fewer full-time equivalent (FTE) employees — paying annual average wages of $25,000 or less. The credit is completely phased out for employers with more than 25 FTEs or with average wages of more than $50,000.
Because the eligibility rules are based in part on the number of FTEs, not the number of employees, businesses that use part-time help may qualify even if they employ more than 25 individuals. More information about the credit, including a step-by-step guide and answers to frequently asked questions, is available on the IRS website.

Two New Benefits for Employers that Hire and Retain Recently Unemployed
Employers who hire unemployed workers this year (after Feb. 3, 2010, and before Jan. 1, 2011) may qualify for a 6.2-percent payroll tax incentive, in effect exempting them from the employer's share of Social Security tax on wages paid to these workers after March 18. In addition, for each qualified employee retained for at least a year whose wages did not significantly decrease in the second half of the year, businesses may claim a new hire retention credit of up to $1,000 per worker on their income tax return.

These tax benefits are especially helpful to employers who are adding positions to their payrolls. New hires filling existing positions also qualify but only if the workers they are replacing left voluntarily or for cause. Family members and other relatives generally do not qualify.
Employers must get a signed statement from each eligible new hire, certifying under penalties of perjury, that he or she was not employed for more than 40 hours during the 60 days before beginning employment with that employer. IRS Form W-11 can be used to meet this requirement. Further details, including answers to frequently asked questions, are posted on IRS.gov.

Work Opportunity Tax Credit Aids Employers That Hire Certain Workers
The work opportunity tax credit (WOTC) offers tax savings to businesses that hire employees belonging to various targeted groups. These groups include people ages 18 to 39 living in designated communities in 43 states and the District of Columbia, recipients of various types of public assistance, certain veterans, ex-felons and certain youth workers. The instructions for Form 8850 detail the requirements for each of these groups.

Certification by the state workforce agency is generally required. Normally, a business must file Form 8850 with the state workforce agency within 28 days after the eligible worker begins work.

An eligible employer can claim both the WOTC and the new hire retention credit for the same employee. However, an employer may not claim both the payroll tax exemption and the WOTC for the same employee. Therefore, any employer that chooses to apply the exemption to wages paid to a qualified employee may not receive the WOTC on any wages paid to that employee during the one-year period beginning on the employee's hiring date.

Exclusion of Gain on the Sale of Certain Small Business Stock
An extra incentive is now available to individuals who invest in small businesses. Investors in qualified small business stock can exclude 75 percent of the gain upon sale of the stock. This increased exclusion applies only if the qualified small business stock is acquired after Feb. 17, 2009, and before Jan. 1, 2011, and held for more than five years. For previously-acquired stock, the exclusion rate remains at 50 percent in most cases.

COBRA Credit
Employers that provide the 65 percent COBRA premium subsidy to eligible former employees can claim credit for this subsidy on their quarterly or annual payroll tax returns. To help avoid imposing an unnecessary cash-flow burden, affected employers can reduce their payroll tax deposits by the amount of the credit.

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© 2010 Thomson Reuters/RIA. All rights reserved.

NEW BUSINESS INFORMATION REPORTING

Effective for payments made after 2011, newly enacted IRC Sec. 6041(h) requires businesses that pay more than $600 during the year to corporate providers of property and services to file an information report with each provider and the IRS. According to recent comments by IRS Commissioner Doug Schulman, the IRS will look for opportunities to minimize burden and avoid duplicative reporting. Specifically, he said that the IRS plans to use its "administrative authority to exempt from this new requirement business transactions conducted using payment cards such as credit and debit cards. These transactions will already be covered by reporting requirements on payment card processors, so there is no need for businesses to report them as well. So, whenever a business uses a credit or debit card, there will be no new burden under the new law." News Release IR-2010-68

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