April 2007 Release that Lien! (Please …) Home-Sale Exclusion for Unforeseen Circumstances Check-the-Box Milestone Overlooks IRS Ability The Rise, Fall and Replacement of the Michigan Single Business Tax Less Rapid Distributions of Rollovers — for Some Release that Lien! (Please …) IRS Collection has certain tools at its disposal when it wants a person to pay up. One of the most common of these tools is a tax lien, and corresponding Notice of Federal Tax Lien. Over the past few years, the IRS has changed the process practitioners use to obtain lien releases. Journal of Tax Practice & Procedure’s Editor-in-Chief, Claudia Hill, provides an overview of federal tax liens and IRS contact information to facilitate obtaining lien releases. Read this article from the Journal of Tax Practice and Procedure Related publications of interest include: IRS Tax Collection Procedures Practical Guide to Federal Tax Practice Standards Federal Taxation Practice & Procedure Was this article useful? Send us your comments: CCH-FocusOnTax@cch.com Home-Sale Exclusion for Unforeseen Circumstances In LTR 200702032, the IRS concluded that a taxpayer who received a damage award for not being notified that the home he purchased—and soon sold—was subject to excessive airplane noise could exclude the award as proceeds from the sale of a home due to an unforeseen circumstance. Under Temporary Reg. §1.121-3T(e)(1), a sale results from unforeseen circumstances if the primary reason for the sale “is the occurrence of an event that the taxpayer does not anticipate before purchasing and occupying the residence.” Find out why the IRS distinguished this taxpayer from the hypothetical homeowner in Example 5 of Temporary Reg. §1.121-3T(e)(4)—who received no mercy for buying a residence on a busy highway—in an article appearing in Federal Tax Course Letter.  Read this article from Federal Tax Course Letter Related publications of interest include: Federal Tax Course: A Guide for the Tax Practitioner Federal Tax Compliance Manual Federal  Tax Guide Was this article useful? Send us your comments: CCH-FocusOnTax@cch.com Check-the-Box Milestone Overlooks IRS Ability 2007 marks the 10-year anniversary of the issuance of the revolutionary check-the-box regulations. Over the past decade, much of the public commentary surrounding these historic regulations concerned solely the classification of LLCs. Yet, the reach of the check-the-box regulations is far greater. Read Richard C. Morris’ article in The M&A Tax Report to find out how the IRS can assert its authority to create an entity for tax purposes out of thin air when legally no entity exists. Read this article from the M&A Tax Report Related publications of interest include: Journal of Passthrough Entities Business Valuation Guide Practical Guide to Mergers, Acquisitions and Business Sales Was this article useful? Send us your comments: CCH-FocusOnTax@cch.com The Rise, Fall and Replacement of the Michigan Single Business Tax The Michigan Single Business Tax is the only tax of its kind, imposed on the privilege of conducting business activity in the state, not on income, and is therefore referred to as a “value-added” tax. Thirty years ago, the primary motivation driving the bold experiment of the SBT was the desire to reduce dramatic fluctuations in revenue directly due to the business cycle and resistant to Michigan’s auto dependant economy. The SBT is repealed effective Dec. 31, 2007, and Gregory A. Nowak, Janelle C. Punch and Rebecca M. Pritchard in an article in Corporate Business Taxation Monthly look backward at the SBT and forward to proposed replacements of the SBT, including calls for a business license tax, a business income tax, a margin tax and even a retail sales tax on new goods and services. Read this article from Corporate Business Taxation Monthly Related publications of interest include: State Income Tax Alert U.S. Master Multistate Corporate Tax Guide Guidebook to Michigan Taxes Was this article useful? Send us your comments: CCH-FocusOnTax@cch.com Less Rapid Distributions of Rollovers — for Some The Pension Protection Act of 2006 engendered a great deal of excitement surrounding Act Sec. 829 and the new ability for non-spouse beneficiaries to perform rollovers of qualified plans to inherited IRAs. This new provision was heralded as the end of mandated quick payouts from qualified plans. However, this excitement was dimmed by the subsequent issuance of Notice 2007-7, which limited the beneficiaries who could take advantage of the life expectancy. Nonetheless, Robert S. Keebler outlines in his column in TAXES—The Magazine how Code Sec. 402( c)(11) still provides a powerful planning opportunity.  Read this article from TAXES — The Magazine Related publications of interest include: Journal of Retirement Planning Retirement Planning Guide Individuals and Small Business Tax Planning Guide Was this article useful? Send us your comments: CCH-FocusOnTax@cch.com CPA Government & Nonprofit Report The CPA’s advisory service on government & nonprofit accounting and auditing Federal Tax Course Letter Plain-English updates on the changing tax scene M&A Tax Report The monthly review of taxes, trends & techniques Corporate Business Taxation Monthly Stay informed on key new business taxation developments Taxes—The Magazine Insightful articles and columns on current tax issues, trends and hot topics Dynasty Trusts Audio Seminar Learn what dynasty trusts are and how they can benefit your affluent clients  Thursday, May 24th at 1pm Eastern, noon Central. Register now for this insightful program!