Federal Tax Reform and Strategy
HOMECopyright © 21st Century Taxation. All rights reserved.
AMT
Simplicity and transparency versus the dread AMT, Silicon Valley/San Jose Business Journal, 12/7/07
Penalty Reform
Penalty Reform, AICPA Tax Insider, 11/12/09
Compliance, Guidance and Paid Preparers
- Categorizing FAQs in the guidance sphere, AICPA The Tax Adviser, 1/1/21
- FAQs: Problems with Informal Guidance from the IRS (2012) by Horwitz and Nellen,
presented to staff of House Ways & Means, Senate Finance, Joint Committee on Taxation, IRS Chief Counsel, Treasury, as well as to National Taxpayer Advocate Nina Olson and her staff,
as part of the California Bar Tax Section DC Delegation activity of May 2012 - National Taxpayer Advocate Office response to a request by Professor Nellen to look into the matter of use of FAQs rather than binding guidance, as a taxpayer rights issue - see 21st Century Taxation blog post of 3/16/11.
- How Heavy is an IRS FAQ?, AICPA Tax Insider, 11/11/10
- Due Diligence Reminders for the 2012 Filing Season, AICPA Tax Insider
IRS and Return Preparers
Articles by Professor Nellen about history and issues of regulating preparers
- Blog post (7/24/14) on IRS Voluntary Registration System Released in June 2014, with links to IRS rule and response from practitioner groups
- Regulating all return preparers: Back to the drawing board; AICPA Tax Insider, 3/13/14
- Can the IRS regulate all return preparers?, AICPA Tax Insider, 10/17/13
- PTIN - Continuing Sequels, AICPA Tax Insider, 6/9/11
- The Competent Tax-return Preparer, AICPA Tax Insider, 3/10/11 (the link in this article has been removed from the IRS web site, but you can find the original material here)
- Yet More Paid Return Preparer Categories!, AICPA Tax Insider, 1/13/11
- Registered Tax Return Preparers, AICPA Tax Insider, 9/10/10
- Regulating Tax Return Preparers, AICPA Tax Insider, 10/15/09
Links related to the Loving case challenging the ability of the IRS to regulate all return preparers
Small Business
- AICPA Position Paper, Recommendations for Tax Law Changes to Reflect How Small Businesses Operate in the Modern World, March 2019 [I was lead drafter and chair of AICPA Tax Exec Committee]
- These recommendations would truly make the tax system simpler for small businesses and reflect how business practices work today.
- Testimony on behalf of the AICPA Tax Section before the Senate Committee on Small Business and Entrepreneurship, Tax Reform: Removing Barriers to Small Business Growth, 6/14/17
- Comments presented to Senate Committee on Small Business and Entrepreneurship Tax Reform Roundtable, 7/17/13
- New Definition of 'Small' Business and Possible Relevance, AICPA Tax Insider, 9/15/11
- Small Business Tax Reform, AICPA Corporate Taxation Insider, 8/28/08
- The Many Sizes of "Small", AICPA Corporate Taxation Insider, 10/28/10
- Small Businesses and Tax Reform - written testimony submitted for the 3/3/11 House Ways & Means Committee hearing on this topic
Worker Classification
Tax Gap
- Property Transactions of Individuals Can Contribute to the Tax Gap, AICPA Tax Insider, 9/13/07
- Closing the Tax Gap, AICPA Tax Insider, 8/14/08
- Rental Real Estate Issues, AICPA Tax Insider, 1/15/09
- Complexity and the Tax Gap - We Can't Just Blame Cheaters for the Gap, blog 1/16/09
- Interesting Reports of 2009, AICPA Tax Insider, 12/10/09
- Narrowing the Tax Gap for Tax Reform, AICPA Tax Insider, 3/14/13
- Wow! IRS Comm'r Rettig Estimates Annual Tax Gap at $1 Trillion, 4/13/21 blog post
Retirement Savings Reform
Health Care and the Tax System
- What individuals need to know about the Affordable Care Act for 2016, AICPA Tax Insider, 2/18/16
- An update on Affordable Care Act busy season developments, AICPA Tax Insider, 3/12/15
- Can individuals on federal exchange claim the premium tax credit?, AICPA Tax Insider, 10/16/14
- Health Care Law Presents New Opportunities for CPAs, AICPA Tax Insider, 2/14/13
- Pot of Gold in the Employer-Provided Healthcare Exclusion, AICPA Tax Insider, 6/12/08 (the benefits of and need to link health care and tax reforms)
Budget Problems
Environmental Taxes
- Know New Taxes (a look at environmental taxes), SF Chronicle, 9/19/07
- Warming up to a Carbon Tax, AICPA Corporate Taxation Insider, 11/29/07
- Policy Considerations of a Carbon Tax, AICPA Corporate Taxation Insider, 12/11/07
- Taxes and Sustainability, Journal of Green Building, Fall 2007
- Green Taxation, AICPA Tax Insider, 9/11/08
- Conflicting Goals - Global Warming and Standard Mileage Rate, blog 11/26/08
- The Greening of the Work of Tax Advisers, AICPA Tax Insider, 5/14/09
- Tax Aspects of Greenhouse Gas Legislation, AICPA Tax Insider, 8/13/09
E-Commerce and New Economy
- Taxation and Today's Digital Economy, CCH's Journal of Tax Practice & Procedure, May-June 2015
- Overview of Internet Taxation Issues , published by Bloomberg BNA Internet Law Resource Center (2014) (95 pages)
- Bitcoin taxation - clarity and mystery, AICPA Tax Insider, 6/12/14
- Real taxes in the virtual economy, AICPA Tax Insider, 8/15/13
- Internet Taxation and Principles of Good Tax Policy (2012)
- Internet Era Questions for Individual Clients, AICPA Tax Insider, 1/10/08
- Overview to federal and state e-commerce tax issues presentation outline 11/3/06
- Let's say goodbye to the Internet tax moratorium Silicon Valley/San Jose Business Journal, 8/10/07 and Portland Business Journal, 8/17/07
- E-Traits
- Chapter from the Internet Encyclopedia, 2004, 11 pages