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CCH Tax Briefing SUPREME COURT STRIKES DOWN DOMA June 27, 2013 Highlights Supreme Court Rules Against DOMA 5 To 4 Joint Returns For Same-Sex Married Couples Tax Refunds Possible “Marriage Penalty” Shared By Same-Sex Couples Estate Planning Strategies Change Employers Expected To Revise Benefit Plans No Nationwide Same-Sex Marriage Mandate Inside Issues At Stake.......................................................2 Supreme Court’s Holdings..................................2 Federal Tax Consequences..................................2 Income Tax Benefits And Disadvantages..........3 Filing Status...........................................................3 Filing Status, AGI Floors And Threshold Amounts..............................................4 Other Same-Sex Couple Income Tax Issues.......5 Estate And Gift Taxation......................................6 Employee Benefits................................................ 7 Affordable Care Act................................................8 Social Security Benefits.........................................9 Effective-Date Issues.............................................9 Special Report Post-DOMA Tax Implications Loom Large In a 5 to 4 decision, the United States Supreme Court has found that Section 3 of the federal Defense of Marriage Act (DOMA) violates the equal protection clause of the Fifth Amendment of the U.S. Constitution as applied to persons of the same sex who are legally married under the laws of their state (Windsor, S.Ct., June 26, 2013, 2013-2 ustc ¶50,400). The majority, written by Justice Anthony Kennedy, held that DOMA is unconstitutional as a deprivation of the liberty of the person protected by the Fifth Amendment of the Constitution. The decision opens the door for same-sex married couples to enjoy many federal taxrelated benefits previously available only to opposite-sex married couples. These include income tax benefits, estate and gift tax benefits, taxpayer-friendly employee benefits, and more. Same-sex couples must now also deal with circumstances under the tax law that may create a so-called “marriage penalty.” Employers must prepare for extensive changes in the treatment of same-sex couples. And individuals claiming tax credits and other provisions under the Patient Protection and Affordable Care Act are impacted by the decision. IMPACT. It is unclear how quickly the IRS and other federal agencies will react to the Supreme Court’s decision …or how quickly same-sex couples may need to act to protect certain rights. President Obama has directed all federal agencies, including Treasury and the IRS, to revise their regulations to reflect the Supreme Court’s decision as soon as possible. Many tax professionals had been advising same-sex couples to file protective refund claims in anticipation of a favorable ruling from the Supreme Court. This is one of several strategies that practitioners and taxpayers should follow up on, as well as filing amended returns before the applicable limitations periods expire on back tax years. The decision to strike down DOMA goes beyond refunds. Same-sex couples need to consider many other tax implications. IMPACT. The Supreme Court did not extend same-sex marriage nationwide; it declined to say whether same-sex couples had a Constitutional right to marriage that would override state law. But the Supreme Court’s decision has opened up federal benefits –including those under the Internal Revenue Code-- to same-sex couples considered married under state law. The Windsor decision leaves many additional issues unresolved or unclear. Among them are the status of “domestic partnerships” and “civil unions” under state law in connection with federal benefits, the status of a same-sex couple married in one state but now residing in a state in which same-sex marriage is not recognized, and the ability of married same-sex couples to divorce without first moving back to a state that recognizes same-sex marriage. CAUTION. Immediately after the Windsor decision was released, questions arose regarding the impact of residency upon the recognition of marital status for federal tax purposes. Will same-sex couples duly married in one state who now reside in a state that does not recognize same-sex marriage be entitled to federal benefits, including being able to file jointly under the federal tax laws? …Or will they be required to file as single under federal law as well as state law? While President Obama on June 27 expressed the view that same-sex marriages performed in one state should apply 2 2013 Expert Analysis to another, he added that “I’m speaking as a president and not as a lawyer.” ISSUES AT STAKE In December 2012, the Supreme Court announced that it would take up two cases related to same-sex couples: Windsor, which arose out of an estate tax dispute between a surviving partner/spouse and the IRS; and Hollingsworth v. Perry (CA-9, Feb. 7, 2012), which addressed whether the equal protection clause of the Fourteenth Amendment to the Constitution prohibits California from defining marriage as the union of a man and woman. The Supreme Court heard oral arguments in both cases in March 2013. IRS Denies Estate Tax Marital Deduction. In Windsor, a long-time same-sex couple married in Canada in 2007. They had previously registered as domestic partners in New York City, where they made their home. One spouse died in 2009. Because of DOMA, the survivor did not qualify for the unlimited marital deduction under the Internal Revenue Code and as a result, the executor of the estate paid $363,000 in federal estate tax that was not otherwise due. The survivor as executor and sole beneficiary filed a refund claim under Code Sec. 2056(a) (under which property of a surviving spouse generally passes free of federal estate tax). The IRS determined that the survivor was not a spouse under Section 3 of DOMA and, therefore, not a surviving spouse under Code Sec. 2056(a). A federal district court found that Section 3 of DOMA violated the equal protection clause of the Fourteenth Amendment because there was no rational basis to support it. The Second Circuit Court of Appeals affirmed the lower’s court decision, finding that homosexuals are a protected class and that Section 3 of DOMA was not substantially related to an important government interest and violated Equal Protection. SUPREME COURT’S HOLDINGS Writing for the majority in Windsor, Justice Kennedy found that DOMA had departed from the long standing tradition and history of reliance on state law to define marriage. The State of New York had recognized the validity of same-sex marriages, which resulted in a status that “is a far-reaching legal acknowledgment of the intimate relationship between two people, a relationship deemed by the State worthy of dignity in the community equal with all other marriages,” Kennedy wrote. He reasoned that DOMA sought to injure this class of persons whom New York sought to protect, and by doing so violated basic due process and equal protection principles applicable to the federal government and was therefore unconstitutional. “The decision opens the door for same-sex couples to enjoy many tax-related benefits previously available only to oppositesex couples.” DOMA’s operation in practice, Kennedy continued, was to treat same-sex marriages as second-class marriages for purposes of federal law “by imposing a system-wide enactment with no identified connection to any particular area of federal law.” DOMA’s principal purpose was to impose inequality, not for other reasons such as governmental efficiency, Kennedy held. Therefore, the majority found DOMA invalid for lack of a legitimate government purpose that could overcome the burden on those within the class whose personhood and dignity New York had sought to protect through its marriage laws. COMMENT: The majority opinion listed numerous ways in which DOMA infringed upon the dignity of same-sex couples. Among these is financial harm caused by DOMA to children of same-sex couples by raising the cost of health care for families by taxing health benefits provided by employers to their workers’ samesex spouses. Another example, Kennedy wrote, is that DOMA denies or reduces benefits allowed to families upon the loss of a spouse and parent, benefits that are an integral part of family security. COMMENT: Justice Kennedy qualified the majority’s ruling at the end of the decision, stating that its applicability was “confined to those lawful marriages,” meaning those recognized by the states that currently allow same-sex marriages. Kennedy observed that Section 2 of DOMA, which allows States to refuse to recognize same-sex marriages performed under the laws of other States, had not been challenged in Windsor and continues to be the law. On June 26, House Democrats introduced legislation to repeal Section 2 of DOMA. California’s Proposition 8. On the same day the Supreme Court announced its decision in Windsor, the Justices ruled, 5-4 (but with a different mix of Justices for and against), to send Hollingsworth back to the California courts rather than to directly decide on the constitutionality of California’s ban on same-sex marriage. There, the Supreme Court held that the petitioners did not have the standing to challenge the lower court’s decision throwing out Proposition 8, which denied same-sex couples the right to marry in California. This decision paves the way for same-sex marriage to begin again in California sometime in late July. FEDERAL TAX CONSEQUENCES Under federal income tax rules, same-sex married couples can now presumably enjoy benefits that had been unavailable to them because of DOMA. On the other hand, certain strategic advantages previously enjoyed by same-sex married couples who filed as single individuals under the federal tax laws, have now likewise ended. COMMENT. Aside from the fact that it was a federal tax refund claim in Windsor that triggered the litigation that found itself before the U.S. Supreme Court, the opinion focused on Constitutional rights and privileges, without any technical CCH Tax Briefing ©2013 CCH Incorporated. All Rights Reserved. June 27, 2013 3 discussion of the tax law itself. The Court judged DOMA for its impact on “over 1,000 federal statutes and the whole realm of federal regulations.” Very little was said specifically about federal tax law beyond that. Nevertheless, the federal tax law is clearly among those “federal statutes and regulations” impacted most directly by the Supreme Court’s holding. IMPACT. Same-sex couples who were married under state law for years prior to 2013 now need to decide whether to amend those prior-year returns still open under the Code’s statute of limitations, to reflect a change from unmarried to married filing status. Same-sex married couples also should consider updating their estate plans, based upon the estate and gift tax impact of Windsor. INCOME TAX BENEFITS AND DISADVANTAGES Because of the Supreme Court’s decision, the same tax benefits and disadvantages faced by just-married, opposite-sex couples—in changing from filing as separate, unmarried individuals to filing as married filing jointly (or married filing separately)—are now shared by same-sex married couples. Likewise, however, those same-sex couples not married under state law continue to be subject to the same disadvantages and benefits, and face many of the same strategic decisions, as unmarried heterosexual couples under the federal tax law. CAUTION. As mentioned, above, resolution is pending on the issue of whether recognition or non-recognition of a samesex marriage in the State in which the same-sex couple currently reside controls whether the IRS will treat the couple as married for federal tax purposes. Most federal agencies have defined marriage in the past based on a couple’s residency and not where they were married. FILING STATUS A taxpayer’s filing status depends in large part—if not exclusively in most cases—on the taxpayer’s marital status. Taxpayers may be single, surviving spouse, head of household, married filing joint returns, or married filing separately. Filing status, in turn, determines the right to many tax benefits, both in terms of access and amount. Income tax rate bracket levels, the standard deduction, personal exemptions, and the adjusted gross income (AGI) amounts at which many tax benefits “phaseout” all hinge upon filing status. Joint Return Status. Because of the Supreme Court’s Windsor decision, same-sex couples who currently are married under state law are presumably now also barred for federal tax purposes from filing separate returns as unmarried (or as head of household, in most cases); they must file either jointly or married filing separately for 2013 (unless they are divorced or have a final separation agreement in place by the end of 2013). The general rule that has always applied to filing status now presumably applies to same-sex married status as well: an individual’s filing status is determined for the entire year based upon marital status on December 31 st of that year. The IRS is expected to issue guidance in this area. IMPACT. Leading up to the Supreme Court’s decision, many same-sex couples filed protective income tax refund claims using married filing jointly status. A protective refund claim is a claim filed to protect the taxpayer’s right to a potential refund based on a contingent event for a taxable period for which the period of limitations is about to expire. Now that the Supreme Court’s decision is out, full refund claims, rather than protective claims, should be filed going forward. COMMENT. Under current rules, a taxpayer can sign a joint return if his or her spouse is serving in a combat zone. In other limited cases where one spouse cannot sign the joint return, such as because of injury or illness, the other spouse may sign the return and attach a statement explaining why the spouse was unable to sign. Same-sex couples who are married under state law are now presumably allowed these signing benefits. COMMENT. Because same-sex marriage is relatively new, the tax implications of divorce of a same-sex couple are only starting to manifest themselves. The Marriage Penalty. Same-sex married couples who have been denied joint return status under the federal tax laws prior to the Supreme Court’s Windsor decision now need to investigate the effect of joint return status, both for returns that will be filed in the future and for prior year returns still open within the statute of limitations refund-claim period (generally, but not always, three years from filing – see this Briefing, below, for a discussion of this deadline). The benefits of filing a joint return may not always be greater than filing separately as unmarried individuals. Both differences in tax rate bracket amounts and a variety of income floors and thresholds used to determine the right to certain tax breaks come into play in determining whether some same-sex couples were better off, income tax-wise, before the Supreme Court’s decision; and what they should do now. IMPACT. Individuals in a relationship who are not married and who each realize approximately the same level of NO NATIONWIDE EXTENSION OF SAME- SEX MARRIAGE The Supreme Court struck down Section 3 of DOMA, which defined marriage as a legal union between one man and one woman as husband and wife and defined spouse as only a person of the opposite sex who is a husband or wife. The Supreme Court did not strike down Section 2 of DOMA, which provides that no state, territory or possession of the United States shall be required to give effect to any marriage between persons of the same sex under the laws of any other such jurisdiction or to any right or claim arising from such relationship. Section 2 was not challenged and, therefore, was not at issue in Windsor. CCH Tax Briefing 4 2013 Expert Analysis income and have similar tax deductions (at least in amount) have generally been better off from a tax standpoint filing as unmarried individuals. However, that assessment tilts in favor of marriage and filing a joint return if one partner earns or deducts the greater portion of any otherwise combined amounts. COMMENT. Although much press was given to “marriage penalty relief” when the Bush-era tax cuts were permanently extended by the American Taxpayer Relief Act of 2012 (ATRA), such relief in fact only related to equality within the standard deduction amount and the top portion of the 15 percent income tax bracket. Other “marriage penalties” continue to exist within the tax law depending upon circumstances. For example, the 33 percent tax bracket for joint filers in 2013 starts at $223,050 taxable income, while the 33 percent bracket for single taxpayers starts at $183,250. If there were no marriage penalty imposed on higher-income individuals earning similar amounts, the 33 percent bracket for joint filers would not start until reaching the $366,500 level, or double that set under the Internal Revenue Code for single filers. Married Filing Separately. If same-sex married couples post-Windsor want to keep their finances (and liabilities) separate for the purpose of filing separate returns, they will generally—but not always—pay more federal income tax. The rate brackets for “married filing separately” are higher than “unmarried, not surviving spouse or head of household.” Innocent Spouse Status. Married taxpayers who file joint returns are jointly and severally responsible for the tax and any interest or penalty due on the joint return. In some cases, a spouse will be relieved of this shared liability for tax owed on a joint tax return. Three types of relief are available: general innocent spouse relief; separate liability relief; and equitable relief. IMPACT. Because of the Supreme Court’s decision, the three types of innocent spouse relief are now presumably available to same-sex married couples. Same-sex married partners cannot turn a blind eye to any item that is listed on a joint return. A decision to file joint returns retroactively for prior tax years as the result of the Supreme Court’s decision, therefore, should include consideration of the joint and several liability that would be triggered. Separate return status would eliminate the issue of joint liability entirely. The IRS is expected to issue guidance in this area. Surviving Spouse Claims. A surviving spouse computes tax using the same rate brackets as married couples filing joint returns. Rules for surviving spouse status for same-sex married couples now presumably follow the same rules as for opposite-sex couples. If a taxpayer is a surviving spouse, the year the spouse died is the last year for which the taxpayer can file a joint return with that spouse. A taxpayer can also qualify as surviving spouse for two tax years following the year in which his or her spouse dies if the taxpayer maintains a household for certain dependents (a child, adopted child, foster child, or stepchild), has not remarried, and filed or could have filed a joint return with the spouse for the year in which his or her spouse died. FILING STATUS, AGI FLOORS AND THRESHOLD AMOUNTS The amounts of income and deductions reported on a return are used by the IRS in determining whether certain threshold levels and floors are reached. Those amounts in turn determine access to a variety of tax benefits. Some of these floors or threshold amounts are applied to all filing statuses uniformly; others vary depending upon filing status. IMPACT. Depending upon adjusted gross income (AGI) and other levels reported on a return, combining the income and deductions of each same-sex partner under a single joint return may or may not work to the advantage of the couple as a unit, in contrast to filing as unmarried or married filing separately.
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2013-Supreme Court DOMA Ruling_June-27-2013_locked.pdf - Epstein Files Document HOUSE_OVERSIGHT_029305

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2013-Supreme Court DOMA Ruling_June-27-2013_locked.pdf - Epstein Files Document HOUSE_OVERSIGHT_029305 | Epsteinify