House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.
House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.
Senator Wyden’s recent ‘discussion draft’ legislation, if enacted, would drastically alter many of the tax rules that apply to partnerships.
Guidance provides procedures to implement the retroactive 30-year ADS recovery period for residential rental property.
IRS concludes that a section 481(a) adjustment retains its character as depreciation when computing a taxpayer’s ATI for section 163(j).
New details of President Biden’s tax plan are shaping congressional negotiations and middle market considerations.
Administration issues Presidential priorities and pay-fors. Corporations and wealthy individuals face prospect of increasing tax rates.
President Biden’s proposed tax changes for individuals and corporations face uncertainty as negotiations continue in partisan environment.
Lingering questions about the timing of President Biden’s potential tax changes, including retroactivity, could soon be answered.
Mexico bans subcontracting arrangements. Companies need to act by Aug. 23 2021 to avoid tax, legal and judicial consequences.
Examining the taxpayer ramifications of President Biden’s proposal to fund IRS enforcement capabilities with an additional $80 billion.
Proposals include a $500,000 cap on gain deferral for like-kind exchanges and eliminating stepped-up basis with a $1 million exemption.
Summary of the American Families Plan and the potential impact that it could have on the real estate industry.
The tax components of the American Families Plan would greatly affect the middle market, but they face a fraught political journey.
Biden’s plan to grow the middle class, expand economic growth and leave the US more competitive, may be funded with tax changes.
The international tax landscape is shifting based on recent reports from the White House, Senate Finance Committee and U.S. Treasury.
Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.
Sweeping changes are coming. Don’t let required capitalization of research expenditures wreak havoc on your tax return.
Mexico released tax changes for 2021. Some new rules may have significant impact on U.S. companies doing business in Mexico.
Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.
IRS modifies guidance on wages that are includible when computing section 199A deduction for taxpayers with short tax years.
Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.
Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.
New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.
The final regulations broaden the definition of real property compared to the more restrictive definition in the proposed regulations.
The IRS will release proposed regulations confirming the SALT deduction limit will not apply to entity-level taxes imposed on pass-throughs.
For corporations with NOLs that anticipate 2021 income, a change of fiscal year may mitigate the impact of the 80% NOL deduction limitation.
Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.
The IRS and Treasury released the final bonus regulations applicable to property acquired and placed in services after Sept. 27, 2017.
The IRS released final regulations affecting S corporations that revoked their status in response to TCJA and lower C corporation tax rates.
IRS releases final and proposed regulations on the deduction for dividends from foreign corporations and related reporting rules.
Former Vice President Joe Biden’s tax plan features significant changes. Rates seem likely to rise, even if President Trump wins re-election
The proposed regulations clarify rules on simplified accounting methods for qualified small business taxpayers.
Final regulations generally taxpayer-favorable versus 2018 proposal, additional proposed regulations give guidance on pass-throughs, others.
The IRS clarifies overpayment claims for tax attributes created or released by carrying back an NOL enjoy an extended limitation period.
Final regulations allow any reasonable method to be applied in calculating deduction amounts allowed under sections 250, 172, and 163(j).
Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.
The new proposed regulations clarify what constitutes ‘real property’ for purposes of section 1031 to help implement changes in TCJA.
Exempt organizations may carryback siloed NOLs to tax years beginning before 2018 and apply them to net unrelated business income.
The CARES Act includes beneficial tax relief. Coupled with sophisticated planning, now is the time to revisit your individual tax strategy.
Procedures provide guidance for the retroactive expensing of qualified improvement property and reconsidering of elections.
Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.
The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.
Immediate and retroactive expensing of qualified improvement property creates tax saving opportunities for taxpayers.
CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships
Coronavirus Aid, Relief and Economic Security Act provides liquidity by providing five-year NOL carryback and other help for corporations.
Tax Policy Now podcast examines filing tax returns now or pursue an extension, given the wait for Treasury Department legislative action.
Guidance provides clarity to current and former small business farmers on procedural options for exemption from UNICAP for certain plants.
Advisor must document amounts used to “investigate” an actual buy or sell – a study may make sense if amounts are substantial.
In early September, Mexico released a proposed tax reform package with significant changes in the country’s international tax regime.
Instructions for claiming a refund or credit, or adjust Form 990-T for qualified transportation fringe of unrelated business income tax.
RSM’s tax leaders bring insight on upcoming policy shifts for the Tax Cuts and Jobs Act in a short audio cast.
The comment letter explains that certain S corporations that experienced an ownership change should also qualify under these rules.
The SECURE Act makes changes affecting retirement benefits in qualified plans and in IRAs for both the employers and individuals.
The IRS has released the final version of Form W-4 reflecting changes to employee withholding from the Tax Cuts and Jobs Act.
Notwithstanding unfavorable changes to the Code, capital gain treatment is still available on the sale of patents in certain scenarios.
The Final QOZ Regulations have been submitted to the Office of Management and Budget for final review and publication is expected soon.
Final regulations affect whether a controlled foreign corporation is a related person under attribution rules.
Comments address concerns and recommendations regarding proposed regulations addressing section 382 built-in gains and losses.
The IRS has published final section 6050Y regulations requiring reporting of sales and acquisitions of certain life insurance contracts.
Favorable rule for corporate stock acquisitions where life insurance contracts are less than 50 percent of the target corporation’s assets.
New IRS enforcement campaign targeting the section 965 transition tax compliance indicates a likely increase in section 965 audit activity.
Revenue Procedure 2019-43 supersedes Rev. Proc. 2018-31, providing procedures to change accounting methods with automatic consent.
The IRS released long-awaited guidance outlining how former S corporations should source distributions between S corp and C corp earnings.
IRS to retain regulations treating some related party debt as equity, but will propose rules easing one of the regulations’ harshest rules.
A business guide to tax considerations for 2019 to help make informed decisions after the Tax Cuts and Jobs Act.
Proposed rules limit the impact and reduce the reporting burden caused by tax reform changes to CFC ownership rules.
A federal district court agreed with the IRS that an S corporation’s AAA balance resets to zero following a switch to C corporation status.
IRS has finalized safe harbor provisions that rental real estate enterprises may use to qualify as a trade or business for section 199A.
Final bonus depreciation rules similar to previously proposed rules, uncertainty remains for certain transactions.
Final and re-proposed regulations released by the Treasury and IRS address important factors for 100% bonus depreciation.
Tax Court allows ordinary business bad debt deduction, rejecting argument that loans not secured by real property were nonbusiness loans.
Passthroughs that have applied the Proposed (not final) GILTI regulations must notify their partners or shareholders to avoid penalties
Rev. Proc. 2019-37 offers procedures for accounting method changes to comply with proposed regulations under sections 451(b) and 451(c).
The much anticipated proposed regulations, under Reg. section 1.451-3, implement section 451(b) and affect nearly every taxpayer.
Proposed regulations would accelerate credit card fee income and similar items, but would not affect most interest income items.
Proposed Reg. section 1.451-8 clarifies how taxpayers can use the section 451(c) method to defer recognition of certain revenue.
Proposed section 382 rules would prohibit section 338 approach for determining NUBIG/RBIG, and require a modified section 1374 approach.
Changes to the built-in gain rules under section 382 would drastically reduce the availability of NOLs following an ownership change.
IRS issues proposed regulations regarding special valuation rules for employee’s personal use of an employer-provided vehicle.
Revenue Procedure 2019-33 provides procedures for taxpayers to make or revoke certain bonus depreciation elections.
Final regulations terminate Reg. Section 1.451-5, which previously allowed multiyear deferral of advance payments for goods and services.
The proposed regulations clarify fixes addressing the “grain glitch” and specify information cooperatives must provide to their patrons.
The Senate recently passed the Taxpayer First Act after eliminating the controversial Free File Program from the bill.
9th Court of Appeals rejects common law “mailbox rule” in favor of section 7502 regulations detailing mailing requirements.
The proposed regulations would impact S corporations owned by ESBTs that have non-resident alien beneficiaries.
Proposed rule would benefit certain purchasers of banks and other C corporations owning life insurance contracts.
Proposed regulations for section 250 deductions provide multi-step process to account for NOL deductions and interest deduction limitation.
Revenue procedure 2019-13 provides a safe harbor for depreciating passenger autos that qualify for bonus but are limited by section 280F.
IRS increased the user fees for certain method changes, and revised the Form 3115 with new filing location, among other changes.
Rental businesses hoping to claim the 20 percent section 199A deduction should consistently apply the trade or business standard.
Under the Bluebook’s interpretation, intent for application of 80 percent limitation was taxpayer favorable.
The IRS has released the final pass-through deduction regs. This is welcome guidance to taxpayers claiming this new 20 percent deduction.
Missing the little known requirement for certain disregarded entities to file a pro-forma tax return could result in substantial penalties.
Corporations' cash refunds of AMT credits would increase under OMB’s decision that automatic federal budget cuts do not apply.
Revenue Procedure 2019-12 provides a safe harbor for businesses to deduct quid pro quo contributions under section 162.
The Token Taxonomy Act would exempt many virtual currency exchanges from taxation and would require virtual currency reporting.
Revenue Procedure 2019-08 clarifies depreciation for electing real property trades or businesses and section 179 expenses under TCJA.
Insurance companies seeking to make a change to the basis of computing certain reserves receive new automatic accounting method change.
Complexity of the Tax Cuts and Jobs Act and technology delays at the IRS may force taxpayers to extend filings.
IRS provides automatic consent for method changes implementing the yet-to-be-clarified revenue recognition rules of section 451(b).
Proposed rules address many open issues and would prescribe complex calculations for taxpayers deducting business interest expense.
IRS Deputy Associate Chief Counsel Daniel McCall said government is working on regulations to correct downward attribution of CFC status.
The IRS issued long-awaited guidance on the treatment of negative amounts subject to capitalization under the simplified UNICAP methods.
Fiscal year pass-through owners may claim DPAD on 2018 return despite repeal for fiscal years beginning after 2017.
The IRS released proposed regulations and a Revenue Ruling providing guidance on the newly created Qualified Opportunity Zones.
Proposed regulations eliminate Reg. section 1.451-5, which provides a method of deferring revenue from advance payments.
A business guide to tax considerations for 2018 and beyond to help the middle market make smart, informed decisions.
Treasury official states income from an SSTB exceeding the de minimis threshold would bar a taxpayer from taking the 199A deduction.
Real Estate Roundtable’s Tax Policy Advisory Committee suggests liberalizations and clarifications to proposed regulations.
Some e-file software does not conform to IRS guidance for S corp shareholders wishing to make a 965(i) election, and they must paper file.
RSM’s report examines how companies are investing in their businesses. In a deeper dive, we explore what manufacturers are considering.
Planned proposed regulations to provide that accrued market discount is not includible in income under section 451(b).
The IRS recently released Notice 2018-67 which provides provisional guidance on the application section 512(a)(6).
Tax Reform 2.0 would make many popular items from the 2017 Tax Cuts and Jobs Act into permanent features of the tax code.
H.R. 6756, the American Innovation Act of 2018, increases the amount of start-up and organizational expenses a business can deduct.
Businesses are spared the effects of proposed regulations intended to curb charitable contributions made in exchange for state tax credits.
The IRS has recently issued Notice 2018-67, providing interim and transition rules for determining UBTI for separate trades or businesses.
Proposed regulations curtail state laws that circumvent the SALT deduction cap by crediting charitable contributions against state taxes.
Rev. Proc. 2018-44 updates the automatic method change procedures to incorporate tax reform’s changes to section 481.
Fiscal year corporations seeking to carry back certain net operating losses gain reason to hope from Committee members’ letter.
Initial thoughts, observations and insights on several key areas of the new pass-through deduction proposed regulations.
The IRS has released proposed regulations containing guidance on several areas of the new 20 percent pass-through deduction.
The Internal Revenue Service releases the proposed regulations under section 168(k) (100 percent bonus depreciation).
Revenue Procedure 2018-40 expands automatic consent procedures for method changes for small businesses in accordance with TCJA.
IRS proposed regulations explain when acquisitions will qualify for bonus depreciation (expensing) under the 2017 tax changes (TCJA).
Exempt corporations with a fiscal year end will be subject to a blended federal tax rate for their fiscal year ending in 2018.
Learn the valuation impacts resulting from the TCJA and its effect on business owners and investors assessment of ownership interests.
Statutory construction principles employed by the Supreme Court again focus on the plain language of statute to determine its meaning.
Corporations anticipating the refundable alternative minimum tax credit may find their refund limited by sequestration.
Mention of “reasonable compensation” in the new 20 percent passthrough deduction isn’t meant to incorporate the S corporation rule.
Notice requires calculation of recognized built-in gain or loss without regard to section 168(k) for ownership changes after May 8.
A look into how to deal with the various tax risks associated with the uncertainty of the Tax Cuts and Jobs Act.
Corporations calculating blended rate federal income tax liability for an affected fiscal year can refer to Notice 2018-38.
Notice 2018-23 provides transitional guidance that delays when governments and governmental entities must report pursuant to section 6050X.
Provision in the Tax Cuts and Jobs Act enacts excise tax on exempt organization compensation paid over $1 million per year.
Join RSM as we discuss how tax reform impacts your entity structure from a federal, international, and state and local perspective.
IRS and Treasury intend to issue Regs to close a perceived loophole that would have excluded S corps from normal three-year hold period.
A review of the most common benefits offered to employees, that are contained, as well as those that are not included in the TCJA.
Accounting methods and other notable items in the second quarter update to the IRS and Treasury’s 2017-2018 Priority Guidance Plan.
Pass-throughs should review their strategy for dealing with self-employment and net investment income taxes as part of new law review.
The tax savings opportunities permitted to operators of privately owned and operated aircraft has been significantly reduced.
Treasury official outlines areas for which guidance will soon be issued to implement the Tax Cuts and Jobs Act.
Section 4968 imposes an excise tax on an applicable institution for each taxable year equal to 1.4 percent of the net investment income.
The FASB recently issued Q&As to address certain accounting issues raised by TCJA. Following is our summary of the FASB Staff Q&As.
Employers have until February 15 to implement new 2018 income tax withholding rates to reflect recent law changes.
A summary of the FASB’s decisions on Jan. 10, 2018 on various income tax accounting issues arising from the Tax Cuts and Jobs Act.
Availability of newly refundable AMT credit carryforwards in light of section 383 credit utilization limitation presents issue.
Refundings of tax-exempt bond issues now treated as taxable income to bondholders under the Tax Cuts and Jobs Act.
Major changes to the treatment of research and experimentation expenditures are coming in 2022 as a result of Tax Reform.
Families may now use section 529 account plans to pay for public, private or religious elementary or secondary school expenses.
Many questions arise for tax-exempts around separate trade or business activities for unrelated business income purposes.
Taxpayers must not overlook acquisition dates or that qualified improvement property is 39-year property and not bonus eligible.
President Donald Trump has signed the recently passed tax bill – the Tax Cuts and Jobs Act (H.R. 1) – into law.
Tax reform has been signed into law. Read RSM’s summary of the major business, international and individual tax provisions.
New corporate tax rules provide benefits, take away significant deductions and generally adds complexity to the corporate tax system.
While the Tax Cuts and Jobs Act generally will lower business income tax rates, businesses with debt financing may see an increased tax bill
Latest version of Tax Cuts and Jobs Act provides some relief to tax-exempts on one hand but eyes big changes on the other.
The IRS and the U.S. Department of the Treasury have released Notice 2017-73, outlining proposed guidance on donor advised funds.
A provision in the Senate tax reform bill will substantially increase penalties related to late filed Form 5472.
Highlights of the provisions in the Senate Committee on Finance proposal that may affect tax-exempt organizations.
The tax reform legislative process was formally kicked off Nov. 2, 2017, with the release of H.R. 1, the Tax Cuts and Jobs Act.
Review legislative changes and other tax concerns that affect 2017 tax compliance and how to plan for 2018. Download our guide.
With the Tax Cuts and Jobs Act signed into law in December, learn what key provisions may impact your tax situation.