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October 3,  2008

Federal Headlines


IRS Issues Guidance to Taxpayers Who Hold Surety Bonds of a Treasury Direct Account (Rev. Proc. 2008-60)

 

The IRS has provided procedures for taxpayers on how to make the election to no longer maintain a surety bond or Treasury Direct Account (TDA) to avoid recapture of the low-income housing credit. The guidance is aimed at taxpayers who are maintaining a surety bond or TDA to satisfy the low-income housing tax credit recapture exception in Code Sec. 42(j)(6), as in effect on or before July 30, 2008. The procedures apply to all taxpayers that disposed of a qualified low-income building on or before July 30, 2008, for which the IRS has approved a Form 8693, Low-Income Housing Credit Disposition Bond. The election is allowed by section 3004(i)(2)(B)(ii) of the Housing Tax Act of 2008 (P.L. 110-289).

 

A taxpayer who seeks to make the election must submit a letter to the IRS containing the following information: (1) the taxpayer's name, address, and taxpayer identification number; (2) a statement affirming that the taxpayer reasonably expects that the building will continue to be operated as a qualified low-income building for the remainder of the building's compliance period; and (3) an "under penalties of perjury" declaration. The taxpayer must attach the signature page of an IRS-approved Form 8693 to the letter and mail to: Internal Revenue Service, Box 331, Attn: LIHC Unit, DP 607 South, Philadelphia Campus, Bensalem, Pa. 19020.

Rev. Proc. 2008-60, 2008FED ¶46,600

Other References:

 

Code Sec. 42

 

CCH Reference - 2008FED ¶4385.72

 

Tax Research Consultant

 

CCH Reference - TRC BUSEXP: 54,222


Additional Relief Provided Employee Benefit Plans in Area Damaged by Hurricane Ike (Notice 2008-87)

 

The IRS, the Department of Labor's Employee Benefits Security Administration ("EBSA") and the Pension Benefit Guaranty Corporation ("PBGC") have provided additional relief to certain employee benefit plans because of damage caused by Hurricane Ike. This additional relief applies to plans located in the Texas counties of Brazoria, Chambers, Galveston, Harris, Jefferson, Liberty, Montgomery or Orange as of September 7, 2008.

Pre-Pension Protection Act Plans

 

For plan years beginning before January 1, 2008, if the date for making a contribution or applying for a waiver falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then the deadline for that contribution or application is postponed to December 15, 2008. In addition, for any plan with an extended contribution date, a contribution for any plan year before the premium payment year may be taken into account if it is made on or before the earlier of: (1) the extended date or (2) the date of the plan's variable-rate premium filing for the premium payment year.

Single Employer Plans

 

For plan years beginning after December 31, 2007, if the date for making a contribution, applying for a waiver, or furnishing a required notice falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then the date for making that contribution, application or notice is postponed to December 15, 2008. If the date for certification of the adjusted funded target attainment percentage falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then the date by which such certification must be made is postponed to December 15, 2008. Moreover, a contribution for any plan year before the premium payment year may be taken into account if it is made on or before the earlier of: (1) the extended contribution due date or (2) the date of the plan's variable-rate premium filing for the premium payment year.

Multiemployer Defined Benefit Plans

 

If the deadline by which a sponsor of an endangered or critical status plan must adopt a funding improvement plan or a rehabilitation plan falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then that deadline is postponed to December 15, 2008. If the date by which the plan actuary must certify whether or not the plan is in endangered status for the plan year and whether or not the plan is or will be in critical status for the plan year falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then the date by which that certification must be made is postponed to December 15, 2008. However, the date by which the sponsor of a plan that is in critical or endangered status must adopt a funding improvement plan or a rehabilitation plan continues to be determined based on the original deadline for the certification of the plan's status.

Notice 2008-87, 2008FED ¶46,601

Other References:

 

Code Sec. 6081

 

CCH Reference - 2008FED ¶36,789.213

 

Code Sec. 7508A

 

CCH Reference - 2008FED ¶42,687C.22

 

Tax Research Consultant

 

CCH Reference - TRC FILEIND: 15,204.25

CCH Reference - TRC FILEBUS: 15,110

 

Tax Court Lacked Jurisdiction over FBAR Penalties, Deficiency Excluded from Notice, and Unassessed Interest (Williams III, TC)

 

Three challenges that an individual raised in connection with his deficiency were dismissed. The Tax Court lacked jurisdiction over penalties imposed under 31 U.S.C. sec. 5321 for the taxpayer's failure to file foreign bank account reports (FBARs) disclosing his Swiss bank accounts. While FBARs had to be filed with the IRS, penalties for failing to file them were not subject to the deficiency procedures that made up the foundation for most Tax Court jurisdiction. Additionally, even if the IRS could use a lien or levy to collect the penalties, and even if the court would have jurisdiction over a challenge to such a lien or levy, the taxpayer had not alleged that the IRS had taken any collection action with respect to the penalties.

 

The court also lacked jurisdiction over a deficiency that arose in a year that was not included in the taxpayer's deficiency notice. Finally, it lacked jurisdiction over his challenge to deficiency interest that had not yet been assessed. Since there was no assessment, there was no IRS decision about abating the interest that would be subject to the court's review.

J.B. Williams III, 131 TC No. 6, Dec. 57,547

Other References:

 

Code Sec. 7442

 

CCH Reference - 2008FED ¶42,058.122

 

CCH Reference - 2008FED ¶42,058.139

 

CCH Reference - 2008FED ¶42,058.151

 

Tax Research Consultant

 

CCH Reference - TRC LITIG: 6,112

CCH Reference -

TRC LITIG: 6,114

CCH Reference -

TRC LITIG: 6,116

 

State Headlines


California --Personal Income, Miscellaneous Taxes: Individuals Subject to Electronic Payment Requirements; Other Changes

 

Legislation subjects specified individuals to electronic California personal income tax payment requirements, accelerates the changes made to the nonresident group return requirements made earlier in the legislative session, expands the Franchise Tax Board's (FTB) collection authority, and increases various alcohol-related license fees.

 
Electronic Payments

 

Applicable to all installments due after 2008, California personal income taxpayers are required to make their tax payments electronically, including utilizing a pay by phone option, if their estimated personal income tax installment payment or extension request payment exceeds $20,000 or if their total annual post-2008 tax liability exceeds $80,000. Taxpayers may make a written election to not make their payments electronically if they did not meet the $20,000 or $80,000 threshold requirements for the preceding taxable year. A penalty of 1% of the tax owed will be imposed against taxpayers who fail to make an electronic payment unless reasonable cause exists. In addition, the FTB may waive the electronic payment requirement if it determines that the particular amounts paid in excess of the threshold amounts were not representative of the taxpayer's tax liability.

 
Nonresident Group Returns

 

With the exception of the effective dates, this legislation also makes changes to the group nonresident return requirements that are identical to those amendments made by Ch. 305 (A.B. 3078) (see TAXDAY, 2008/09/29, S.3), thereby allowing group nonresident returns to be filed on behalf of a single nonresident shareholder or partner, and allowing nonresident shareholders and partners with taxable incomes in excess of $1 million to be included in the nonresident group return. However, as a result of the urgency clause contained in this legislation these changes will go into effect earlier and are applicable beginning with the 2008 taxable year.

 
Other Changes

 

Finally, additional amendments made by this bill (1) reinstate the FTB's authority to collect delinquent assessments and penalties that are levied against employers for violation of specified labor and occupational safety and health laws and (2) effective January 1, 2009, increase various license fees imposed under the Alcohol Beverage Control Act.

Ch. 751 (A.B. 1389), Laws 2008, effective September 30, 2008, and applicable as noted above.

 

Virginia --Sales and Use Tax: Dates Announced for Second Annual Energy Sales Tax Holiday

 

Gov. Tim Kaine has issued a press release announcing that Virginia's second annual sales tax holiday on energy efficient products will take place October 10-13, 2008. During the sales tax holiday period, purchases of certain Energy Star and WaterSense qualified products purchased for non-commercial use and costing $2,500 or less will be exempt from sales tax. These products include energy efficient products such as compact fluorescent light bulbs, ceiling fans, clothes washers, dehumidifiers, dishwashers, programmable thermostats, refrigerators and room air conditioners, and water efficient products such as certain toilets and faucets.

 

A complete list of exempt items, answers to frequently asked questions, guidelines for the sales tax holiday, and additional information is available from the Virginia Department of Taxation at http://www.tax.virginia.gov/site.cfm?alias=EnergyStarQualifiedProductsHoliday.

 

The governor's press release is available at http://www.governor.virginia.gov/MediaRelations/NewsReleases/viewRelease.cfm?id=791.

Press Release, Office of Virginia Governor Tim Kaine, October 2, 2008.

 

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