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TCJA
Tax Cuts and Jobs Act of 2017; established a flat 21% corporate tax rate.
FATCA
Foreign Account Tax Compliance Act; requires reporting of foreign financial assets.
Worldwide Income
U.S. citizens and residents are taxed on income earned anywhere in the world.
Tax Liability
Amount of tax owed.
Tax Base
Amount subject to tax.
Average Tax Rate
Total Tax ÷ Taxable Income.
Effective Tax Rate
Total Tax ÷ Total Income.
Marginal Tax Rate
Tax rate on the next dollar earned.
Progressive Tax System
Tax rates increase as income increases.
Proportional Tax
Same tax rate regardless of income level.
Regressive Tax
Effective tax rate decreases as income increases.
C Corporation
Corporation that pays its own income tax.
Pass-Through Entity
Business whose income flows through to owners for taxation.
S Corporation
Pass-through corporation governed by Subchapter S.
Partnership
Pass-through entity whose income flows to partners.
Schedule K-1
Reports an owner's share of income, deductions, and credits from a partnership or S Corporation.
16th Amendment
Constitutional amendment that authorized federal income taxation in 1913.
Internal Revenue Code (IRC)
Primary federal tax law.
Primary Authority
Legal authority that can support a tax position (IRC, regulations, court cases, rulings).
Secondary Authority
Research materials that explain tax law but generally cannot be cited as authority.
Treasury Regulations
Official Treasury interpretations of the Internal Revenue Code.
Revenue Ruling
IRS interpretation of tax law applied to a specific situation.
Revenue Procedure
IRS guidance on administrative procedures.
Letter Ruling (PLR)
IRS guidance applicable only to the taxpayer requesting it.
Tax Treaty
Agreement between the U.S. and another country to prevent double taxation.
Municipal Bond Interest
Generally exempt from federal income tax.
Corporate Bond Interest
Taxable interest income.
FICA
Federal Insurance Contributions Act taxes that fund Social Security and Medicare.
Social Security Tax
Payroll tax of 6.2% for employee and 6.2% for employer.
Medicare Tax
Payroll tax of 1.45% for employee and 1.45% for employer.
Self-Employment Tax
15.3% tax paid by self-employed individuals.
NIIT
Net Investment Income Tax; 3.8% tax on certain investment income.
Additional Medicare Tax
Additional 0.9% tax on high-income taxpayers.
FUTA
Federal Unemployment Tax Act tax; paid only by employers.
Gift Tax
Tax on transfers made during life.
Estate Tax
Tax on transfers made at death.
Ad Valorem Tax
Property tax based on value.
Horizontal Equity
Similar taxpayers should pay similar taxes.
Vertical Equity
Taxpayers with greater ability to pay should pay more tax.
Sufficiency
Tax system raises enough revenue to fund government operations.
Equity
Tax system should be fair.
Certainty
Tax laws should be understandable and predictable.
Convenience
Taxes should be easy to pay.
Economy
Cost of collecting taxes should be low.
Adam Smith's Five Canons
Sufficiency, Equity, Certainty, Convenience, and Economy.
Tax Avoidance
Legal reduction of taxes through proper planning.
Tax Evasion
Illegal failure to pay taxes owed.
Budget Deficit
Government spending exceeds government revenue.
Treasury Bills
Short-term government debt instruments.
Treasury Notes
Intermediate-term government debt instruments.
Treasury Bonds
Long-term government debt instruments.
Fiscal Sustainability
Government's ability to pay future obligations.
Single Filing Status
Unmarried taxpayer filing an individual return.
Married Filing Jointly (MFJ)
Married couple filing one joint return.
Married Filing Separately (MFS)
Married spouses filing separate returns.
Head of Household (HOH)
Unmarried taxpayer supporting a qualifying dependent.
Qualifying Surviving Spouse
Special status available after a spouse's death.
Individual Return Due Date
April 15.
C Corporation Due Date
April 15.
Partnership Due Date
March 15.
S Corporation Due Date
March 15.
Extension
Gives more time to file but not more time to pay tax.
Statute of Limitations
Time period IRS has to audit or taxpayer has to amend a return.
General Statute Rule
3 years.
25% Omission Rule
6-year statute of limitations.
Fraud Statute
Unlimited statute of limitations.
Correspondence Audit
IRS audit conducted through the mail.
Office Audit
Audit conducted at an IRS office.
Field Audit
Audit conducted at taxpayer's business or home.
DIF System
IRS scoring system used to select returns for audit.
Information Matching Program
IRS system that compares returns to W-2s, 1099s, and other forms.
Document Perfection Program
IRS system that checks for math and clerical errors.
30-Day Letter
IRS notice allowing taxpayer to request an appeals conference.
IRS Appeals Conference
Meeting with IRS Appeals Officer to resolve disputes.
90-Day Letter
Statutory Notice of Deficiency allowing taxpayer to petition Tax Court.
Statutory Notice of Deficiency
Formal IRS notice giving taxpayer 90 days to go to court.
Tax Court
Federal court allowing taxpayers to challenge tax before paying.
District Court
Taxpayer must pay tax first and sue for a refund.
Court of Federal Claims
Taxpayer must pay tax first and sue for a refund.
Stare Decisis
Doctrine that courts follow prior decisions.
Golsen Rule
Tax Court follows the precedent of the applicable Court of Appeals.
Eleventh Circuit
Federal appellate circuit covering Georgia, Florida, and Alabama.
House Ways and Means Committee
House committee that initiates tax legislation.
Senate Finance Committee
Senate committee responsible for tax legislation review.
Joint Conference Committee
Committee that resolves House and Senate bill differences.
Open Facts
Tax transaction has not yet occurred; planning opportunities still exist.
Closed Facts
Tax transaction already occurred; only consequences can be analyzed.
Tax Research Process
Facts → Issues → Authorities → Analysis → Conclusion → Communication.
Internal Memo
Internal tax research document used within a firm.
Client Letter
Tax explanation written to a client in plain language.
Circular 230
IRS rules governing professionals who practice before the IRS.
AICPA Code of Professional Conduct
Ethical rules governing CPAs.
SSTS
Statements on Standards for Tax Services.
State Board of Accountancy
Agency regulating CPA licenses.
Civil Penalty
Monetary penalty for violating tax rules.
Criminal Penalty
Penalty that may include fines or imprisonment.
Substantial Authority
Approximately 35-40% chance a tax position would be sustained.
Reasonable Basis
Tax position supported by at least one reasonable authority.
Form 8275
Disclosure form for questionable tax positions.
Income From Whatever Source Derived
General rule that income is taxable unless specifically excluded.