Summary
Rules that disallow safe harboring of all of a preceding years income have just gone into effect for estimated tax payments for 2d qtr 1992. IRC 6654 affects those with adjusted gross incomes (AGI) of more than $75,000 or an increase in AGI of $40,000 or more if they made a tax payment or paid a penalty during the last three years. Entities where no current interest exists do not provide pass through benefits in calculating modified AGI. There is some indication that the IRS will show some latitude in interpreting these rules.
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Extract
Special estimated tax rules.
Special estimated tax rules that deny certain individuals the use of the 100% of preceding year's income safe harbor become effective for second quarter 1992 estimated payments. The special rules apply to taxpayers with adjusted gross income (AGI) for the current year of more than $75,000, and "modified AGI" for the current year that ...
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