Blog

0

Some Perspective (from an Unexpected Source) In Defense of the IRS’ Notice 2016-66

IRS Notice 2016-66 requiring dealers to file Forms 8886 to disclose Producer Owned Reinsurance Company (PORC-like activities) has created considerable uncertainty over what should be filed and by [...]

0

Are PORCs on the IRS’ Endangered Species List?

Just wondering if anyone has heard anything within the last few weeks about the IRS Notices regarding the status of PORCs as “abusive” tax shelters and the related filing requirements with OTSA. [...]

0

Head’s-Up … A Significant Filing Date for Forms 8886 Is Approaching

Almost a decade has passed since IRS activities involving PORCs (that’s Producer-Owned Reinsurance Companies) rose to a level of general awareness of automobile dealers’ CPAs. It appears the IRS [...]

2

Taxation of VW Settlement Payments: Don’t Expect Any Advance IRS Guidance

On February 14, I participated in a follow-up conference call / discussion hosted by Paul Metrey of NADA (Vice President, Regulatory Affairs) involving several CPA firms whose input NADA sought [...]

0

Court Approval of VW-Dealer Settlement Still Leaves Taxation Question Unanswered

On January 23, U.S. District Judge Court Breyer gave the Court’s final approval to the Volkswagen settlement, holding that “the settlement is fair, reasonable and adequate.” The Court evaluated [...]

0

Tax Return Disclosures … Is Form 8275 Indispensable?

A recent article (in Tax Notes, posted today 1/19) by two San Francisco attorneys, entitled “Tax Return Disclosures: What Is Adequate and Why It Matters,” provides a comprehensive discussion [...]

0

TPR Anxiety

With the recent flurry of activity regarding 2014 tax returns and the Section 263(a) Tangibles Regulations (Rev. Proc. 2015-20), I find myself feeling conflicted about what I should be doing ... [...]

0

Sleeper Alert! – IRS GLAM Re: Auto Dealer Facility Upgrade

Seemingly out of nowhere, the IRS released Legal Advice on the taxation of auto dealer facility image upgrade payments to dealers. It comes as no surprise that the IRS concluded that these [...]

0

The Sequester – Lemons Or Lemonade

One of the benefits of being at the AICPA Auto Dealership Conference is the opportunity to catch up and talk shop with many friends. While talking about how some in the press have been lamenting [...]

0

The Final Tangibles Regulations: Expense Or Capitalize? … At A Glance

I've seen a lot of summaries on the new / Final Tangibles Regulations that were published yesterday in the Federal Register. They all seem to basically just repeat the overview of the Regs that [...]

page 1 of 2

Disclaimer

De Filipps University, Willard J. De Filipps, CPA, PC, and Willard J. De Filipps reserve the right to determine the appropriateness of all comments and responses. Comments and responses may not be posted, per the discretion of De Filipps University, et al. All submissions that are posted will be anonymous, without any Member identification included for public viewing; however, anonymous submissions will not be considered.

IMPORTANT NOTICE: The information and comments included on this web site are intended to provide accurate, general information on dealer tax and LIFO matters and they should not be construed as offering accounting or legal advice or accounting or legal opinion on any specific facts or circumstances. The contents are intended for general information purposes only. Readers should consult their certified public accountant, attorney and/or other competent advisors to discuss their own situations and specific dealer tax and LIFO questions. Mechanical or electronic reproduction or photo capture reproduction is prohibited without permission of Willard J. De Filipps, CPA, PC.

Nothing contained on this web site or within this blog shall be construed as a binding obligation or waiver of rights of Willard J. De Filipps, CPA, PC. The formation of any contract, waiver of terms of an existing contract, or acceptance of notice may only be accomplished in a physically signed writing executed by an authorized representative of Willard J. De Filipps, CPA, PC.

IRS Circular 230 Disclosure: To ensure compliance with Treasury Department regulations, we inform you that any U.S. Federal tax advice contained on this web site (including any pdf-linked documents) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

Contact Us

We're not around right now. But you can send us an email and we'll get back to you, asap.

Start typing and press Enter to search