The Tax Court’s decision in Paschall, (2011) 137 TC No. 2 held that the statute of limitations for assessing the excise tax on excess contributions to a Roth IRA remains open where a taxpayer fails to report the contributions on his return. The excess contributions in the case were caused by an attempt to use a so-called “Roth restructure” transaction to disguise excess contributions to the taxpayer’s Roth IRA. The taxpayer also was held liable for additions

The Tax Court has held in Estate of Lillian Baral, (2011) 137 TC No. 1 that payments made to caregivers for providing physician-ordered assistance and supervision to a patient suffering from dementia qualified as long-term care services under Code Sec. 7702B(c) and were thus deductible amounts paid for medical care under Code Sec. 213(d)(1)(C). The Beliveau Law Group: Massachusetts | Florida | New Hampshire The attorneys at The Beliveau Law Group provides legal services for estate planning

In PLR 201126023 the IRS has ruled that (1) the domestication of a foreign corporation would be considered a reorganization under Code Sec. 368(a)(1)(F); (2) such domesticated company could elect to be considered an S corporation on the date it became domesticated; and (2) the trusts that wholly-own the domesticated corporation were eligible to elect to be treated as electing small business trusts (ESBTs). Source: International Tax Updates on Checkpoint Newsstand The Beliveau Law Group: Massachusetts |

Beginning July 1, the 0.2% federal unemployment tax (FUTA) surtax is no longer in effect. The surtax was part of the 6.2% gross unemployment tax rate that employers pay on the first $7,000 of wages paid annually to each employee (6% permanent tax rate, 0.2% temporary surtax). The surtax had been in effect in every year since 1976, when it was enacted by Congress on a temporary basis. The FUTA tax rate, before consideration of state