3 Are accountable to your personal computer as a .pdf. The Madoff Tax Losses – Maybe the Safe Harbor Worth it? Much has been discussed the two documents released by the I.R.S. Ponzi schemes. There is Revenue Ruling 2009-9 (the “Rev. Rul.”) where the I.R.S. Likewise there is a Revenue Procedure 2009-20 (the “Rev. Proc.”) which provides an uncomplicated path through the law and you will be helpful to thousands of Madoff victims who’ll have a brief path to cash refunds from taxes losses. This will be sorely needed by many.

This is provided in what the I.R.S. Both documents by IRS are a good package deal and drafted in record time for any government agency. The I.R.S. worked well. HOWEVER, IT IS IMPORTANT TO REMEMBER IRS IS NOT IN BUSINESS TO PROVIDE BACK MONEY. The “safe harbor” needs to be carefully researched since it is a safe harbor that may be extremely expensive from a taxes standpoint. It might be a safe harbor however the tax cost to dock your fishing boat in this harbor could be high. ONE VERY SIMPLISTIC EXAMPLE.

30 Billion ofMadoff losses that might be able to get theft loss taxes benefits. Believe this Madoff quantities or income of the principal, when taxed were in the best tax brackets. It is because most earners of Madoff phantom income acquired other resources of taxable income. Therefore, to keep it simple again, assume the average taxes bracket is 35% for the Madoff income contained in prior years. Assume these Madoff losses are deducted in 2008 and used against income for the years 2003 through 2007 as reduction carry backs from the robbery loss deduction.

This means that Madoff income and Madoff investments of principal which have been taxed at the highest mounting brackets will be transported back and applied against all of the income in a particular year. To a big extent these losses will offset income in each prior year that was earned at lower rates. The quantity of any refund from the loss carry are affected accordingly back again. 7.5 Billion). In this particular full case the I.R.S. 10.5 Billion in tax revenue for a long time without paying interest.

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For reasons like this and for many other situations many Madoff victims may never choose to avail themselves of the safe harbor of Rev. Proc. 2009-20. This is especially so since the legal guidance offered by Rev. Ruling 2009-9 is so helpful. I’ve chosen to use the Chart on the following page to describe and compare the effects of the Revenue Ruling and the Safe Harbor.

I also have attached both the Ruling and the task as an Appendix. I believe the Chart shows that for most taxpayers the “tax privileges” that must be waived to consider the benefit of the “tax benefits” of the safe harbor could be very expensive and unneeded. Many taxpayers will see that the tax benefits available by relying on the Revenue Ruling and the state of regulations are more suitable alternatives to the advantages of the safe harbor. Prior to the issuance of Revenue Ruling 2009-9 there was a great deal of case laws interpreting various aspects of the theft loss deduction.

= $ =p>The full cases, were at times 40 to 50 years of age and many reflect the absence of the type of forensic accounting that may be accomplished today. Because of this and others, though there was a great deal of case regulation interpreting the rules and statutes, there remained a great deal of misunderstandings on where certain lines were attracted.