Tax Update Blog: December 2003 Archives

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CARNIVAL AT YEAR-END

December 29, 2003

The "Carnival of the Capitalists" is a weekly roundup of weblog posts on business topics. This week's installment has worthwhile pieces on Health Savings Accounts, a new twist on "dead peasants" insurance, and the ever-pressing issue of Kangaroo culling. Check it out.

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2003 COMES DOWN TO THE WIRE

December 26, 2003

2003 ends at midnight Wednesday, and as far as we can tell, extensions are unavailable. What's a procrastinator to do?

TAX MOVES THAT ARE PROBABLY WISE

-Sell enough of your investment losers to offset your capital gains.

-If you have a business, and you intend to buy new capital assets soon, get them in service by December 31 to take advantage of 50% bonus depreciation and the expanded Section 179 deduction.

-Pay your last-minute deductions with checks mailed by December 31 or by credit card charges incurred before January 1 (even if the credit card bill is paid later). For the generous procrastinator, a number of worthy charities will take online contributions via credit card, including the Salvation Army and the USO.

-If you have a business, remember that amounts accrued to related parties must be paid by December 31 to be deductible this year (unless both you and the related party are on the accrual method).

-If you have a money-losing S corporation, be sure you have enough basis to deduct your losses.

-Pay your next mortgage payment by December 31 so you can deduct your interest.

-If you will be paying for a child's college education, make a contribution for the child to a College Savings Iowa account or another Section 529 plan by year-end. College Savings Iowa contributions made by year-end are deductible on your Iowa return up to $2,230 per donee, per child.

-If you have an estate likely to be large enough to be subject to estate tax, make your $11,000 per donee gifts before Thursday. If you don't use this year's annual gift exclusion, it's lost forever. Don't count on the mail for this - get the goods to the happy donees before you toast the new year.

TAX MOVES THAT MAY OR MAY NOT BE WISE

-If you expect to owe state income taxes and you're pretty sure you won't incur Alternative Minimum Tax (AMT) for 2003, you may want to mail an estimated state tax payment by December 31.

-If AMT is unlikely, consider paying your March property tax bill by December 31 so you can deduct it.

-Remember - if you have income over $125,000, or if you have three or more children, or large capital gains, it is unwise to assume that you won't have AMT for 2003 unless you have run some numbers to make sure.

TAX MOVES THAT AREN'T WORTH MAKING JUST FOR TAXES

-If you become a parent before the ball drops on New Years Eve (local time), you will have a dependent exemption for the entire year. Good luck convincing Mom to hurry it up, though; and if she finds out that the deduction is useless anyway because of AMT, she might be really irate.

-Your marital status on December 31 is your marital status for the entire year, as far as the tax law is concerned. Some folks are better off (for taxes) married; some aren't. If your marriage decision hinges on the tax consequences, you probably should be visiting another website.

A GOOD TAX MOVE WE HOPE YOU WOULD MAKE ANYWAY

-Survive. The lifetime exemption for the Estate Tax increases to $1,500,000, from the current $1,000,000, for those dying after December 31. Unfortunately, the gift tax exemption will remain at $1,000,000 after 2003.

So hang in there, and have a great 2004.

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THE IRS AIN'T SANTA CLAUS

December 23, 2003

The IRS mailed Yancy K. Young a $500 refund he didn't ask for and wasn't entitled to. When they realized their mistake, they asked for it back. Mr. Young apparently had grown fond of the $500, and declined to return it.

The issue ended up in Tax Court, where Mr. Young made the novel argument that the payment was a "gift" from the IRS. Just in time for Christmas, the Tax Court settled the issue:

Petitioner contends that respondent’s erroneous refund was a gift to him. While respondent has the authority to make a refund of overpayments, see sec. 6402(a), we are unaware of any provision that authorizes him to make gifts. Furthermore, we would be hard pressed to find that respondent made the payment based on a detached and disinterested generosity, out of affection, respect, or admiration of petitioner so as to constitute a gift.

Well, you can't blame a guy for trying...

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IOWA INTEREST RATE DROPS TO 6%

December 23, 2003

The interest rate charged and paid by the Iowa Department of Revenue on tax underpayments and overpayments will drop to 6% for 2004 (ARC 2991B, no link available). It was 7.2% in 2003.

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IRS ISSUES Q&A DISCUSSION OF HEALTH SAVINGS ACCOUNTS

December 22, 2003

The IRS has posted a discussion of the new Health Savings Accounts (HSAs) in its website (Notice 2004-4; pdf format).

HSAs are IRA-like accounts that can receive tax deductible contributions from individuals and make tax-free distributions to cover medical expenses. The become available in 2004.

The notice answers a number of practical questions. For example, it states that HSA trustees will not be required to verify that distributions are for qualified medical expenses; HSA beneficiaries will have to document the qualifed expenses.

You can also find our introduction to HSAs here.

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AMT: IT'S FOR EVERYBODY!

December 18, 2003

Commentators are piling on the alternative minimum tax (AMT).

Today's Wall Street Journal Tax Report (subscription required) reports that Taxpayer Advocate Nina Olson will call the AMT "the most serious problem encountered by taxpayers" in an upcoming report. "It's a train wreck," Ms. Olson says.

The article also forwards helpful advice from Len Burman, co-director of the Tax Policy Center, on avoiding AMT:

"Get rid of your children, and move to a low-tax state."

The USA Today weighs in with Tax cuts may push some families into AMT trap (thanks to BenefitsBlog for the pointer):

The AMT was created in 1969 to prevent the super-rich from using sophisticated loopholes to avoid paying taxes. But because it wasn't indexed to inflation, the number of taxpayers who fall into the AMT net has increased. In 2003, an estimated 2.4 million taxpayers will pay the tax. Unless Congress changes the law, up to a third of all taxpayers will grapple with the AMT by the year 2010

We have discussed the AMT here and, more recently, here.

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ANOTHER FLIGHT ANNIVERSARY

December 17, 2003

The Wright Brothers made their historic flight 100 years ago today, starting a chain of events culminating in exclusive First Class passenger lounges.

Today is also the anniversary of another momentous flight. On December 17, 1990 an intrepid band of accountants took flight from their national firm nest to start Roth & Company, P.C. 338 payrolls later, we still haven't had to get real jobs, thanks to our wonderful clients, employees and friends. It's great to work with you.

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JANUARY 2004 AFRS ARE OUT

December 17, 2003

The IRS has issued (Rev. Rul. 2004-2) the minimum interest rates for loans made in January 2004:

Short Term (demand loans and loans with terms of 1-3 years): 1.71%
Mid-Term (loans from 3-9 years): 3.52%
Long-Term (over 9 years): 5.01%

Historical AFRs are available on the “Links” page at www.rothcpa.com.

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YEAR-END TAX TIP: CHARITABLE GIVING

December 17, 2003

When doing your 1040, it is always better to have given than to have received. If you plan to give to some good causes, here are some tips to make sure you receive some tax benefits:

- Make gifts of appreciated long-term capital gain property. Such gifts are deductible at full fair market value, and the appreciation is never taxed. Publicly traded stocks are the easiest items to transfer, but you shouldn't wait until the last minute - brokers and charities sometimes can be slow to execute such gifts.

- Look at your collectibles. The top federal capital-gain tax rate for stocks is 15%, but the top rate for coin collections, classic cars, and baseball cards is 28%. This means donations of appreciated collectibles save nearly twice as much tax as donations of stock. But remember:

- Donations of items other than publicly-traded securities require appraisals when they exceed $5,000. No deduction is allowed without a signed Form 8283 attached to your tax return.

- Iowa has a special break for donations to Community Foundations. A tax credit of up to 20% is available for certain gifts made to community foundations, such as the Greater Des Moines Community Foundation or the Greater Cedar Rapids Community Foundation. These "Endow Iowa" credits are in addition to the regular deduction for the gifts. If you are charitably inclined, these credits are a great incentive to keep your money in your community.

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A DEDUCTION FOR DENNIS?

December 17, 2003

A taxpayer (we can't very well call him a "lucky" taxpayer under the circumstances) recently won a victory in the Tax Court when he was allowed to exclude from income a portion of a payment received from Dennis Rodman. The $200,000 payment settled a lawsuit filed after Mr. Rodman kicked the taxpayer in the groin during an NBA game.

WHITHER THE RODMAN 1040?

The important question arises: does Mr. Rodman get to deduct the payment?

Surprisingly, examples of fines for athlete mayhem are relatively rare in the tax law. The only case we can find dealing directly with payments by athletes for infractions involves Garnet Bailey, formerly of the Boston Bruins and St. Louis Blues.

Thse Bailey court outlined the hurdles a payment must clear to be deductible for a wayward athlete.

-It must be incurred in the trade or business of the taxpayer. Mr. Rodman's payment would seem to meet this requirement, in that the groin-kicking occured at work.

-It must not be a nondeductible fine or penalty. Code Section 162(f) forbids deductions for fines or penalties paid to a government. As Mr. Rodman paid his victim, not the government, this hurdle is cleared.

-The payment must be "ordinary and necessary" in the taxpayer's trade or business. If anyone could argue that settlements for assault are an ordinary and necessary business expense, it might be Mr. Rodman.

For a payment to be "ordinary," the Supreme Court has said "It is the kind of transaction out of which the obligation arose and its normalcy in the particular business which are crucial and controlling." For an expense to be "necessary," it must be “appropriate and helpful” in the taxpayer's business.

While Mr. Rodman may have felt the payment arose out of what was, to him, an ordinary business occurrence, which he may have even considered appropriate and helpful, one could expect the courts to be sceptical. Mr. Garnet, a hockey player, was unable to win a deduction for his fines paid to the NHL for fighting. If fighting isn't ordinary and necessary for a hockey player, it isn't for anybody.

OTHER OBSTACLES

We also shouldn't overlook the tendency of judges to deny deductions for things that just seem wrong. For example, the Tax Court denied an author certain expenses incurred in researching a book on the grounds that some expenses are just "so personal in nature as to preclude their deductibility." The disallowed expenses were payments to prostitutes made during research for a book about legal brothels in Nevada.

EVEN IF HE WINS, HE LOSES

Were Mr. Rodman to clear all of these hurdles, he still might not get full benefit from his payments. As Mr. Rodman's expense was incurred in the trade or business of being an employee, it would be a "miscellaneous itemized deduction." These provide a tax benefit only to the extent that all such deductions exceed 2% of adjusted gross income. One source puts Mr. Rodman's 1997 salary at about $4,500,000. If this were his only income, his miscellaneous deductions would be deductible only to the extent they exceed $90,000. To add insult to injury, they would not be deductible at all in computing alternative minimum tax.

GARNET BAILEY FOOTNOTE

After his NHL career ended, Garnet Bailey became scouting director for the Los Angeles Kings. He was on United Flight 175 from Boston on September 11, 2001 when it was crashed into the World Trade Center.

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IRS INTEREST RATE REMAINS AT 4 PERCENT FOR FIRST QUARTER 2004

December 15, 2003

The IRS announced that the interest rate for underpayments and overpayments will remain at 4% for the first quarter of 2004. The rate for corporate overpayments will remain at 3%, and the rate for large corporation underpayments will remain at 6%. (Rev. Rul. 2003-126)

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IRS SYSTEMS MODERNIZATION: DOOMED, BUT ON THE RIGHT TRACK?

December 12, 2003

The IRS Oversight Board has been watching the Service's efforts to bring its data processing out of the electronic stone age. It's conclusion: flint and bone tools will have to do for awhile longer.

The IRS has had a "Business Systems Modernization" plan in place for some years. The report says "...last summer, the BSM program appeared at the point of unraveling. Virtually all of the projects with a major impact on improving customer service and IRS' internal operations and productivity were experiencing serious delays and cost overruns."

The Report goes through a litany of blown deadlines and overruns, but concludes, in effect, that we're up the creek, so we just have to keep paddling. The report recommends that the IRS reduce the scope of its modernization ambitions and try to get one important thing right - the "Customer Account Data Engine" (CADE), the super-database of taxpayer account information that will drive all of the other systems.

The report also warns the prime contractor of the project, Computer Sciences Corporation (CSC), that it is on thin ice:

Although the Board observed ongoing improvements in CSC's program management and some of its management processes, overall results did not change. Target dates and budgets continued to be consistently missed. In addition, CSC should have addressed much earlier many of the other issues previously discussed in this report.

The Board discussed this very serious concern with Commissioner Everson. While he also has misgivings about CSC's performance, he believes that he has established a strong working relationship with its executive management and has its complete commitment to work with the IRS to address previous shortfalls. While the Board accepts this conclusion, we believe that the Prime's performance must be monitored very closely and if significant improvements are not demonstrated quickly, a change should and must be made.

In addition, the report offers a number of other recommendations that look to us non-technical folk like they were produced by Dilbert's Mission Statement Generator. For example:

Recommendation 3: Enhance the systems development life cycle methodology to support more accurate estimates of future work phases and put into place the necessary processes to insure that the methodology is followed religiously. Again, this work is under way.

Recommendation 4: Enhance the program's contracting process and capabilities.

The Board also concludes that the basic system design is ok, if they can just figure out how to get it in place. Looking on the bright side, maybe it's reassuring that Big Brother lacks the competence to run a comprehensive database on all of us...

The Systems Modernization Team at work?

The report is not yet up on the IRS Oversight Board site.

UPDATE: It is now. (pdf format)

UPDATE: Dave Gross (see comment below) has a discussion on his site from a tech-guy point of view.

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BUT THE WEB SITE SAID IT WOULD WORK!

December 11, 2003

Detect the flaw in this plan:

"According to the complaint, Bishop and Fuller’s customers paid an initial fee of $7,500 to participate in the scheme. The customers, who are self-employed professionals or business owners, then terminated their employment relationship with their own company and contracted with a purported Barbados “employee-leasing” company - Global Executive Placement, Ltd. - to hire them and “lease” their services to a U.S.-based company, Executive Placement Services, a company that Bishop and Fuller own. Executive Placement Services then “leased” the customers’ services back to the customers’ own company."

If you noticed that the plan requires the IRS to be willfully stupid, give yourself a pat on the back. This plan only works if the IRS is willing to believe that executives would really work for nothing on behalf of an offshore leasing company - and pay $7,500 for the privilege. Maybe the IRS is not entirely staffed with MENSA members, but that's asking a lot of stupidity. Then again, somebody was paying the $7,500.

PERMANENT INJUNCTION - THE IRS SEAL OF APPROVAL?

This plan came to light because the promoter of the plan, Cornerstone Strategic Advisors, LLC, was hit this week with a permanent injunction against promoting or implementing such plans.

They are apparently still game, though. While all references to the leasing plan seem to be gone from their website, they still are promoting an "S Corporation Strategy"-

"This strategy allows for tax avoidance on personal services income through year-end, 2005. The strategy is typically implemented by establishing a management company, to provide management services to the taxpayer's operating business at 'reasonable compensation' levels. The income is tax deferred from the outset and grows tax-free through the deferral period and is fully liquid and in the control of the taxpayer."

Gee, this sounds oddly familiar... think the IRS will buy it? Given the promoter's track record, scepticism seems in order.

Maybe they will explain to their potential customers, "Hey, there's no injunction against this one, so that means it's OK!" Buy only from promoters under permanent injunction, that's the ticket!

A PDF file of the injunction order is here.

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MOM RESIGNS

December 10, 2003

Last January, Pamela Olson, Assistant Treasury Secretary for Tax Policy, became the surrogate mother to unruly tax shelter promoters with this pronouncement:

"The IRS knows about the transactions and has done nothing to shut them down so obviously things are copacetic, right? Wrong. We can argue about whether promoters should have known the difference between approval and neglect. But, many did not understand that – or they chose to believe otherwise – and so tax practice deteriorated without adult supervision.

"Well, folks, the parents have arrived at the party."

The Treasury announced Ms. Olson's resignation today. The resignation will take effect on the completion of the pending budget.

With the earlier resignation of the apparent father, B. John Williams, foster care arrangements for the tax shelter promoters are pending.

Ms. Olson holds three degrees from the University of Minnesota, which may be more than the Gopher men's basketball team earned during the 1990s.

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THE NEW HEALTH SAVINGS ACCOUNTS: HOW THEY WORK

December 08, 2003

The Medicare legislation to be signed into law today includes a controversial approach to health insurance coverage: the "Health Savings Account," or "HSA."

The HSA program encourages individuals to adopt high-deductible policies by allowing deductible contributions to a personal self-insurance reserve - the HSA. Earnings in the HSA accumulate tax free; they can be withdrawn tax-free to pay medical expenses. Penalty-free taxable withdrawals of amounts not used for medical expenses may be made after age 65.

Supporters say several good things will come from HSAs:

-Consumers will spend health dollars more carefully if there is a larger deductible before insurance kicks in;

-Administrative costs will be reduced because routine expenses won't be paid by the insurance company.

-Savings will be encouraged because taxpayers will get to keep HSA amounts not spent.

Backers say health insurance under an HSA will work something like car insurance: State Farm doesn't process a claim for an oil change, and Geico doesn't cover your tune-up; why should Wellmark cover your flu shot?

We will leave others to sort out the policy implications of HSAs. The important issue is, what's in it for us on April 15?

WHO QUALIFIES?

Taxpayers need to have a "high deductible" health insurance policy to qualify. This means:

- a deductible of at least $1,000 for single coverage or $2,000 for family/joint coverage.

-The out-of-pocket maximum per year cannot exceed $5,000 for single coverage and $10,000 for family/joint coverage.

-The taxpayer cannot be covered by a non-qualifying policy for items covered by the high-deductible policy.

HOW MUCH CAN I CONTRIBUTE AND DEDUCT?

-Individuals (self-only coverage): the maximum contribution and deduction is the lesser of $2,600 or the annual policy deductible

-Families: lesser of $5,150 or the annual deductible

-Taxpayers over 55 can contribute an additional $500.

-There is no phase-out for high-income taxpayers. This is one of the controversial aspects of the HSA as enacted.

WHAT ABOUT EMPLOYER CONTRIBUTIONS?

Employers can contribute to HSAs to the extent contributions by an employee would be deductible. To the extent the employer funds an HSA, the employee may not make a contribution. Employer contributions are tax-free to the employees.

HOW CAN I GET AT MY HSA SAVINGS WITHOUT PENALTY?

HSA savings can be withdrawn tax-free to cover medical expenses. They can be withdrawn as taxable distributions without penalty at age 65, or if the taxpayer is disabled. Other withdrawals are subject to a 10% early withdrawal penalty.

As a practical matter, many taxpayers will pay their out-of-pocket medical expenses with after-tax non-HSA dollars, allowing their HSAs to accumulate as a tax-deferred savings vehicle.

WHAT ABOUT MY MEDICAL SAVINGS ACCOUNT (MSA)?

Taxpayers with MSAs will find that the HSA is very similar in concept to the MSA. MSAs are limited to employees of small companies and to self-employed taxpayers. While the MSA rules are unaffected by the HSA legislation, it is likely that many MSA owners will shift to the less restrictive HSA format. MSA owners will be able to roll their existing accounts into HSAs tax free.

WHEN CAN I START AN HSA? HOW?

The HSA legislation takes effect for 2004. Interested taxpayers should consult their employers about whether their coverage includes a high-deductible option. Self-employed taxpayers and employers can already find high-deductible plans from, among others, Golden Rule Insurance and Wellmark. Because it will be much easier to qualify for HSAs than the old MSAs, insurers are likely to respond with more high-deductible policy choices.

Insurers have provided trustee services for MSA accounts. If HSAs catch on, more banks and mutual fund companies are likely to trustee MSAs.

UPDATE: a Treasury fact sheet on HSAs is here.

UPDATE II: Aetna had a full-page ad in the December 9 Wall Street Journal for their new HSA product. It will be interesting to see whether this catches on.

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YEAR-END PLANNING TIP: BEWARE THE ALTERNATIVE MINIMUM TAX

December 04, 2003

What do these Iowans have in common?

- A three-child household with two parents earning $95,000 each.
- A widow with a large capital gain.
- A single doctor with taxable income of $200,000 and a new house.

Your choices:

A): They wish Slipknot and Yanni would work out their creative differences.
B): They TIVO the House Ways and Means Committee hearings on C-SPAN.
C): They are likely to incur alternative minimum tax (AMT) this year.

As odd as it seems to some of us, "C" is the correct answer. The new tax law lowered the regular tax rates, with 35% now the highest regular rate. The AMT rates, however, were not lowered. The top stated AMT rate remains 28%, but deduction phaseouts make for a 35% marginal rate at some income ranges. AMT is computed with fewer deductions, exemptions and credits than regular tax; it applies if it exceeds the regular tax. Now that the regular rates are closer to the AMT rates, the AMT will apply more often.

WHAT TO DO?

A number of taxpayers are doomed to AMT, but others might avoid it by careful planning. Some ideas:

Project your 2003 and 2004 income taxes. It's asking a lot to compute your taxes now when you have to do it for real in April, but a good projection is essential for AMT planning.

Match your state income tax payments with your income. State and local taxes are not deductible in computing individual AMT. Taxpayers with unusually high income this year - say, as a result of a big capital gain - are much more likely to have AMT next year if they don't prepay some of their state taxes before December 31. The two-year projection can tell them how much state tax to prepay.

WHAT IF YOU ARE STUCK WITH AMT ANYWAY?

Sometimes AMT is unavoidable. If so, you should avoid some of the standard tax planning tricks. For example, you shouldn't prepay your March property tax installment, and you should wait until January to pay your fourth quarter state estimated taxes.

Some standard tax planning tricks still help when AMT strikes. You may reduce AMT if you:

-Take capital losses to the extent of capital gains, plus $3,000.

-Make charitable contributions with appreciated property.

-If you own a Schedule C or pass-through business, accelerate business deductions.

ACCELERATE INCOME?

A few taxpayers - if they are sure they have AMT this year and will be top-bracket regular taxpayers next year - may even want to move some income from 2004 up to 2003. This strategy might make sense because the 28% top AMT rate is lower than the 35% top regular tax rate. This requires reasonably predictable income and a good projection. Don't try this at home, kids.

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THE TAX CONSEQUENCES OF BEING KICKED IN THE GROIN BY DENNIS RODMAN

December 01, 2003

Remember Dennis Rodman? Eugene Amos surely does. Mr. Amos suffered an unforgettable workplace injury at the hands - well, the foot - of "the Worm."

Mr. Amos was working the sidelines in Minneapolis as a television cameraman for a January 1997 visit by the world-champion Bulls. Mr. Rodman fell over the cameraman out-of-bounds and expressed his regret with a kick to Mr. Amos's nether region. Mr. Amos was removed on a stretcher.

Mr. Amos went directly to a hospital, where he demonstrated his mental toughness by contacting an attorney before leaving. Mr. Rodman quickly came to terms, agreeing to a $200,000 settlement six days after the game.

WAS IT PHYSICAL?

Mr. Amos excluded the $200,000 from gross income on his 1997 return on the grounds that it was compensation received "on account of personal physical injuries or physical sickness," which is tax-free under Code Sec. 104(a)(2). The IRS disagreed, saying Mr. Amos failed to demonstrate actual physical damage.

The settlement agreement was vague about whether the settlement was for physical damages. When a settlement doesn't clearly spell out what is being settled, the tax law looks to the "origin of the claim" to determine whether it qualifies for exclusion. Tax Court Judge Chiechi dodged the need to determine whether a kick in the groin by Mr. Rodman (6-6, 220 lbs.) was harmful, noting that as long as physical harm was the basis for the claim for damages, there was no need to prove that actual damage resulted. Ruling that the claim was primarily for physical damages, the court allowed Mr. Amos to exclude $120,000 of the award (T.C. Memo. 2003-329).

Oh, and the Bulls won, 112-102.

THE WORM TURNS?

Mr. Rodman received an 11-game suspension and a $25,000 fine from the NBA. Could Dennis qualify for a tax deduction for the league fine and settlement? We'll address that next time.

UPDATE: The tax consequences to Mr. Rodman are addressed here.

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