The column, appearing in Monday's issue of Tax Notes, the weekly magazine on federal tax policy and administration, will focus on current tax issues at the intersection of policy and practice. Karlinsky has a wide range of interests in the tax field that have developed over the last 40 years, and he hopes to share his perspectives with the tax community. He intends to avoid politics and instead examine the fairness, complexity, administrability, and tax law aspects of the debate. The column will also appear in Tax Notes Today, Tax Analysts' federal daily online publication.
Karlinsky's first column will address why and how the materially participating passive activity loss rules of 1.469-5T(e) might be applied to simply and fairly treat managing members of LLCs regarding self-employment taxes. He points out that the proposed treatment would be consistent with Congress's intent in the 1977 enactment of section 1402(a)(13). He will examine the recent Renkemeyer decision and point out there is a difference between a stealth tax and enforcing compliance with the intent of Congress. The approach he identifies could also be used by the IRS in audit selection and resolution regarding S corporation owner-employee undercompensation.
In future columns, Karlinsky will discuss such issues as the three-year vs. six-year statute of limitations rules relative to the 25 percent understating of gross income under section 6501, given the recent decision in Mayo; badly needed back-to-back loan guidance for S corporation basis loss rules; how to simplify the compliance burden for lower-income taxpayers with a prefiled tax return regime; and what our international tax world would look like if we used financial statement income for corporations.
About the Author
Stewart S. Karlinsky is professor emeritus and former graduate tax director at San Jose State University. He is currently the executive director of the Pacific Rim Tax Institute and was previously at the High Technology Tax Institute.
Karlinsky received his PhD and MBA from New York University and his BBA from Bernard M. Baruch College of CUNY. He teaches, writes, and speaks on tax policy regarding corporate, individual, and real estate taxation, the alternative minimum tax, S corporations, reorganizations, international taxation, and closely held business taxes. He has been an expert witness for both prosecution and defense and has testified before Congress on the AMT. He has served as a Fulbright senior specialist at two universities in Ireland. He has taught international tax, tax policy, and comparative tax systems in the United Kingdom, France, Austria, Portugal, Australia, and Ireland, and has published over 85 articles in professional and academic journals.
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