The Court of Appeals for the Third Circuit in Battoni v. IBEW Local Union 102 Employee Pension Plan held that a change in a welfare plan amounted to, in effect, an unlawful cutback of participants’ benefits in a pension plan in violation of the anti-cutback provisions of ERISA and IRC §411(d)(6). The matter in question involved the merger of two locals of the International Brotherhood of Electrical Workers (IBEW) and their plans. Prior to the merger, IBEW Local 675’s pension plan permitted beneficiaries to choose between a lump sum retirement benefit or periodic payments, while Local 102’s plan (which was to be the surviving plan) did not provide for such a benefit. The combined pension plan provided that members of Local 675 retained the right to take a lump sum payment, but only for benefits accrued prior to the merger. Continue Reading »
Posted in Tax | Tagged pension plan, Qualified Plans | Leave a Comment »
Details of the tax proposal in the President’s 2011 budget proposal are described in the Treasury Department’s “Green Book,” more formally known as the General Explanations of the Administration’s Fiscal Year 2011 Revenue Proposals. The 153 page document is available from the Treasury Department’s website as a PDF file. Continue Reading »
Posted in Tax | Tagged estate tax, tax proposals | Leave a Comment »
As some had surmised was likely to happen, the IRS is getting ready to make use of the data regarding uncertain tax positions being assembled by entities to comply with FIN48 (now in FASB ASC 740-10). The IRS announced that it is considering requiring business taxpayers with total assets in excess of $10 million that have financial statements prepared to which FIN48 is applicable to give more detailed disclosures of uncertain tax positions. Announcement 2010-9 the IRS has asked for comments to be submitted by March 29, 2010. The IRS expects to issue a schedule on which the disclosures will be made, and the disclosures will be required on returns filed after the schedule is released. Continue Reading »
Posted in Tax | Tagged Dislcosure, FIN48 | Leave a Comment »
http://online.wsj.com/article/SB10001424052748703906204575027320135790934.html?mod=rss_whats_news_us_business Reading this on your Blackberry? Try The Wall Street Journal Mobile Reader now by clicking http://www.wsjmobilereader.com.”
Posted by J. Michael Stolp from my Verizon BlackBerry Storm 2.
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Posted by J. Michael Stolp from my Verizon BlackBerry Storm 2.
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The Tax Court took a look at what represents adequate disclosure and a reasonable basis for a position in the case of Campbell v. Commissioner, 134 TC No. 3. Continue Reading »
Posted in Tax | Tagged 6662, disclosure, reasonable basis | Leave a Comment »
In response to the earthquake in Haiti, Congress has unanimously enacted the Haitian Assistance Income Tax Relief Act. That bill contains three provisions that apply to contributions for Haitian earthquake relief. Taxpayers may elect to treat any contribution made after January 11, 2010 and before March 1, 2010 as if it were made on December 31, 2009. To qualify the contributions must be made in cash, has to be made for the relief of victims in the areas affected by the earthquake in Haiti on January 12, 2010 and for which a charitable contribution is allowed under IRC §170. Continue Reading »
Posted in Tax | Tagged 170, charity, haiti | Leave a Comment »
John Armbrust (Armbrust v. Commissioner, TC Summary Opinion 2010-5) ran into what appears, even to the Tax Court, to be a rather arbitrary distinction between funds received from an IRA and a qualified plan. However, the Court found that the law was clear and it had no choice but to subject the entirety of John’s plan distribution used for acquisition of a new home to the 10% tax on premature distributions. Continue Reading »
Posted in Tax | Tagged IRA, IRC Section 72, Qualified Plans | Leave a Comment »
Posted by J. Michael Stolp from my Verizon BlackBerry Storm 2.
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You may find this video very clever.
A palindrome reads the same backwards as forward. This video reads the exact opposite backwards as forward. Not only does it read the opposite, the meaning is the exact opposite. This is only a 1 minute, 44 second video and it is brilliant. Make sure you read as well as listen both forward and backward.
This is a video that was submitted in a contest by a 20-year old. The contest was titled “u @ 50″ by AARP. This video won second place. When they showed it, everyone in the room was awe-struck and broke into spontaneous applause. So simple and yet so brilliant.
Take a minute to watch it.
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