IRS Provides Section 9100 Relief for Late-Filed NOL ElectionWayne R. Strasbaugh
Since 1986, the IRS has offered electronic filing of tax returns in order to reduce operating costs and paper usage. However, not all items can be filed electronically, including the Section 83(b) election statement. The IRS is proposing to change its...
Regulation 1.645-1(f)(1) provides that the Section 645 election period begins on the date of the decedent's death and terminates on the earlier of the day on which both the electing trust and related estate, if any, have distributed all of their assets, or the day before the "...
The U.S. Internal Revenue Service (IRS) has provided rules in this Section to make it easier for tax payers in the election. Further, Section 108(i) allows eligible taxpayer to elect COD income with respect to the "reacquisition" of an applicable debt instrument.Lipton...