Lower income means harsher treatment from the government for taxpayers who claim the Earned Income Tax Credit (EITC). EITC claimants are audited more often than any taxpayers other than the very wealthy. More concerning, however, is that the IRS audits EITC claimants by correspondence...

Invoking allusions to Caligula and Roman tax law, the Sixth Circuit, in Summa Holdings, reversed the Tax Court and held that the Commissioner could not use the substance-over-form doctrine to prevent taxpayers from combining the tax savings effects of a domestic international sales corporation...

Although increasing access to higher education has been a priority of the federal government for more than half a century, the government has largely shifted the way in which it offers assistance over the last two decades from grants to loans. In the aftermath of the dot-com and mortgage debt...

Funding higher education is among the critical financial decisions made by individuals and families. There are myriad options. Yet, the conventional wisdom — namely using Section 529 Plans — may not be the optimal vehicle to effectuate this goal. Therefore, this Article discusses various...

Tax planning and compliance challenges may arise for taxpayers who utilize 529 plans to pay for qualifying education expenses and subsequently receive refunds as a result of COVID-19. This article examines the scenarios taxpayers may be faced with and options available to help preserve the...

Develops a new methodology for estimating the value of federal, state and local tax exemptions received by private, nonprofit higher-educational institutions, using Northeastern University as a demonstration case study

This article considers two unrelated tax provisions – healthcare Flexible Spending Accounts (FSAs) and the charitable deduction. FSAs permit eligible taxpayers to set income aside tax-free to use for medical expenses. However, these accounts have a “use-it-or-lose-it” feature that...

This Estate and Gift Tax Rap column for Tax Notes is an extended discussion of the United States District Court (W.D. Pa.) decision in Estate of Palumbo v. U.S.. In that case, the court upheld a claimed estate tax charitable deduction for amounts passing to charity pursuant to a settlement of a...