This Alert summarizes impacts of the recently-issued interest deduction limitation guidance on the real estate industry.
This Alert summarizes impacts of the recently-issued interest deduction limitation guidance on the real estate industry.
Amendments to section 162, 164, and 170 regs. formalize safe harbors for payments to charitable organizations in exchange for SALT credits.
An executive order was issued directing the deferral of payroll tax payments. Follow up guidance from the Treasury Department is expected.
The IRS postponed the first quarter filing and payment deadline for federal sporting goods excise taxes until Oct. 31, 2020.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
Eligible businesses that did not receive certain other COVID-19 relief may qualify for grants up to $250,000.
New legislation allows nonprofit employers to pay 50% of their unemployment reimbursing payment obligations to states.
The department found the business did not engage in qualifying research or submit proper documentation to substantiate the claim.
The court ruled that DOL regulations unduly restrict paid leave, thus expanding the eligibility of FFCRA paid leave.
Proposed carried interest regulations are mostly as expected with a few new items and detailed computational rules.
The proposed regulations clarify rules on simplified accounting methods for qualified small business taxpayers.
Notice 2020-59 proposes a revenue procedure clarifying real property trade or business elections for residential living facilities.
These treasury regulations affirm the statutes the IRS will use to assess, reconcile, and recapture the COVID-19 payroll tax credits.
Treasury proposes clean up to air trans excise tax regulations and rules to exempt payments by aircraft owners to management companies.
Finalized legislation will evolve but the proposal is a starting point for bipartisan negotiations for a new round of economic relief.
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.
Seattle payroll expense tax to be imposed on employee compensation of at least $150,000 for businesses with $7 million or more in payroll.
Final and proposed regulations related to the GILTI high tax exclusion and subpart F high tax exception released.
The Federal Reserve Board has established two new loan facilities to expand credit options for nonprofit organizations.
Final regulations allow any reasonable method to be applied in calculating deduction amounts allowed under sections 250, 172, and 163(j).
The Community Development Financial Institutions Fund announces over $3.5 Billion in New Markets Tax Credit allocation.
Taxpayers that properly secured a first extension may file a request for a second extension on or before Aug. 17, 2020.
Notice 2020-56 extends until Dec. 31, 2020, the due date for CHNAs or implementation strategies due on or after April 1, 2020.
Treasury and the IRS have issued final regulations on determining the amount of the deduction for FDII and GILTI.
TEGE will resume exam activities on July 16, 2020 and will allow agents and managers to exercise discretion in granting IDR extensions.
Changes to NOL rules under the TCJA and CARES Act are implemented for consolidated corporate groups under new proposed regulations.
Temporary regulations provide election filing procedures to implement retention of NOL tax benefits by acquiring consolidated group.
Revenue Procedure 2020-37 lists depreciation limits for owners and lessees of passenger automobiles placed in service or leased in 2020.
California Office of Tax Appeals determined that a construction company could not use a resale certificate for material purchases.
Congress extends PPP timeline for approved applications through Aug. 8, 2020; SBA releases data set of borrower information.
DOL proposes prohibited transaction exemption for Financial Institutions and Investment Professionals providing advice to participants.
Expanded eligibility ending Nov. 30, 2020 presents an opportunity for businesses to come into compliance with certain state taxes.
IRS explains taxability of Provider Relief Fund reimbursements made to health care providers pursuant to the CARES Act.
The revised sales tax nexus standards reduce the current $500,000 threshold to $100,000 beginning Oct. 1, 2020.
The previous June 30 deadline to carryback 2018 NOLs on Form 1139 and Form 1045 has been extended to July 15.
Mississippi will require marketplace facilitators to register to collect and remit sales and use taxes beginning July 1, 2020.
The state will decouple from the taxpayer-friendly interest expense and net operating loss provisions of the federal CARES Act.
The Sixth Circuit held that the DOJ should have been permitted to provide evidence regarding a taxpayer’s historic R&D credit information.
Due to the COVID-19 pandemic and economic crisis, the IRS will permit employers to adopt midyear amendments to plan contribution formulas.
Expansive tax bill provides taxpayer-friendly changes while balancing reduced tax revenue in the COVID-19 economy.
Fiscal year 2021 budget includes temporary tax changes in order to generate much needed revenue in the COVID-19 economy.
New York enacts legislation further decoupling New York City corporate and UBT taxes from certain CARES Act provisions.
Notice 2020-51 affords welcome additional flexibility for individuals to deal with required minimum distributions they took in 2020.
TTB FAQs allowing for the destruction of beer off brewery premises and waiver of notice of intent to destroy were extended through Sept. 1.
Refundable credit receives taxpayer-friendly updates, including increased availability and extended application deadline and sunset dates.
Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.
The proposal concerns ERISA plans that make investment decisions based on environmental, social and corporate governance (ESG) factors.
SBA / Treasury release additional changes to Interim Final Rules that further clarify loan forgiveness process.
Delaware notices advise businesses to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
The TTB now allows tobacco proprietors to file their special occupation tax online via the agency’s Permit Online program.
The IRS extended the second quarter filing and payment deadline for federal sporting goods excise taxes until Oct. 31, 2020.
Guidance relating to the application of the Cares Act to coronavirus-related distributions and loans from retirement plans.
The IRS issued guidance clarifying the definition of gross receipts for tax-exempt employers utilizing the employee retention credit.
The proposed regulations provide long-awaited guidance for the disallowance of qualified transportation benefits and commuting expenses.
The Office of Tax Appeals determined that the taxpayer did not show that it undertook a process of experimentation.
SBA/Treasury release various guidance items over the past week; updated and streamlined loan forgiveness applications.
Louisiana will require marketplace facilitators to register and collect and remit the state and local sales tax beginning July 1.
Notice 2020-46 provides guidance for cash payments from foregone vacation, sick or personal leave made by employers to charities.
The new proposed regulations clarify what constitutes ‘real property’ for purposes of section 1031 to help implement changes in TCJA.
OIRA has begun reviewing the FDII and GILTI deduction regulations and the final regulations are expected to be released soon.
Section 4960 proposed rules add examples and clarity while generally following interim guidance and providing taxpayer-friendly exceptions.
AICPA requests electronic signatures on additional tax forms, easing the burden of manual signatures for taxpayers and preparers.
The recent IRS Notice provides relief in the form of flexibility for investment timing and testing periods for QOFs and their investors.
Exempt organizations may carryback siloed NOLs to tax years beginning before 2018 and apply them to net unrelated business income.
In a request for comments, the service outlines potential calculation methods – but also suggests disallowing an extremely common method.
Long awaited proposed regulations clarify a number of open questions that remained with the carbon sequestration credit.
IRS FAQs outline procedures for alien individuals in U.S. to claim the medical condition exception to avoid U.S. resident status.
Retroactive law changes found in the CARES Act raise questions on the proper timing for adjusting corporate E&P.
PPP legislation extends covered period for loan forgiveness and Congress amends 75% payroll requirement; bill heads to President Trump.
President held personally liable for unpaid income tax withholding even after another corporate officer found responsible.
Plan participants may use an electronic system facilitating remote notarization or witnessing if executed via live audio-video technology.
TTB adopted, with minor changes, temporary regulations on alcohol tax filing dates implementing 2015 PATH Act for eligible excise taxpayers.
Final regulations promulgated under section 6033 reduce Form 990, Schedule B reporting for certain exempt organizations.
The IRS released proposed regulations that clarify five-year rehabilitation credit period created by the Tax Cuts and Jobs Act.
IRS Notice 2020-41 grants an extension to place renewable energy property in service and expands a safe harbor for beginning construction.
The IRS has issued updated questions and answers regarding CARES Act employee retention credits for employers impacted by COVID-19.
Deadlines postponed for certain employment taxes, employee benefit plans, IRAs, HSAs, MSAs and other time-sensitive actions.
Questions and answers about how NOL carryback refund claims should address AMT calculations are now available on the IRS’ website.
The IRS announced the addition of 2019 Form 1040X to the library of electronic filings beginning this summer.
Services performed in Detroit for clients located outside the city should be sourced to Detroit for purposes of the city’s income tax.
Treasury released guidance indicating that references to NAFTA can be interpreted as USMCA for purposes of U.S. tax treaties.
SBA releases authoritative loan forgiveness guidance as well as SBA loan review procedures and borrower responsibility.
IRS issues new release detailing limited resumption of certain operations and advising taxpayers on alternatives for inoperative functions.
In response to the COVID-19 crisis, the European Commission has formally proposed the deferral of certain deadlines under DAC6.
Delay in ASC 606 for private companies that have not yet issued financial statements may have tax implications.
The Louisiana Sales and Use Tax Commission announced guidance for remote sellers exceeding the nexus thresholds beginning July 1, 2020.
Write-off of capitalized IPO costs after a go-private transaction disallowed because the costs do not create a separate and distinct asset.
TTB issues new guidance in Q&A format about tax-free withdrawals of distilled spirits and hand sanitizer under the CARES Act.
PPP loan forgiveness application provides clarity on measuring payroll periods, eligible costs and loan forgiveness reduction calculations.
The elective tax is intended as a state and local tax deduction limitation workaround, joining six other states with similar provisions.
New TTB FAQ addresses requirements for a winery holding remote wine tastings with customers, including tax, labeling, and container sizes.
A recent IRS private letter ruling granted an extension of time for the required certification of a Qualified Opportunity Fund.
Finalized section 385 debt-equity regulations proposed in 2016, government still plans to issue some less harsh rules in the future.
SBA continues to issue guidance on PPP loan repayment criteria; however more loan forgiveness guidance is necessary.
IRS released CARES Act FAQs on aviation excise tax holiday. FAQs provide clarification on issues related to jet fuel and ticket tax.
Proposed regulations, issued on May 12, 2020, address changes enacted in TCJA to section 162(f) and the addition of section 6050X.
While rent forbearance may provide lessees with much needed cash, tax implications should be carefully considered.
Proposed regulations provide guidance on treatment of administration expenses and treatment of excess deductions in the year of termination.
The IRS released a proposed revenue procedure intended to update existing rules with respect to obtaining and maintaining a group exemption.
When determining whether an S corp distribution is a dividend, Arkansas taxpayers must use state-specific AAA rather than federal AAA.
Employers should use the updated Form 941 to properly report new CARES Act and FFCRA credits beginning in the second quarter of 2020.
The IRS updated the Economic Impact Payment FAQ to include guidance for returning payments made to deceased taxpayers.
Taxpayer-friendly measures provide interest waivers, extension of limitations periods and assistance to impacted businesses.
TTB issued FAQs providing guidance for refund claims on taxpaid beer for brewers when unmerchantable beer is destroyed during COVID-19.
IRS issued Rev. Proc. 2020-29, which temporarily allows taxpayers to electronically request private letter rulings.
Notice 2020-32 disallows deductions for expenses paid with loan proceeds from the PPP when loan forgiveness occurs.
The IRS provided additional guidance regarding fax submissions of tentative carryback claims, Forms 1139 and 1045.
Time in U.S. counts as time in a foreign country under foreign earned income exclusion for taxpayers who returned to U.S. due to COVID-19.
The Arizona Court of Appeals upheld a lower court finding that a CEO was responsible for unremitted transaction privilege tax.
Congress authorizes additional $310 billion for PPP; SBA issues additional eligibility guidance for hedge funds and private equity.
The U.S., Cayman, and other jurisdictions extend deadlines for filing FATCA and CRS reports, but exams and compliance programs continue.
The COVID-19 pandemic may relieve recipients of tax incentives from the recapture provisions under the Nebraska Advantage Act.
Treasury and the IRS release long-awaited guidance to exempt organizations under section 512(a)(6) for separately computing UBTI.
The ability to revoke elections and file amended returns means partnership may have more than one option to benefit from CARES Act.
Nonresident alien individuals unable to leave the U.S. because of travel restrictions may avoid U.S. resident status under new IRS guidance.
TTB has extended its waivers for certain distilleries wishing to produce hand sanitizer through the 2020 calendar year.
Emergency regulations and technical guidance provide clarifications for telecommuter withholding and nexus safe harbors.
Procedures provide guidance for the retroactive expensing of qualified improvement property and reconsidering of elections.
IRS considers revoking 10 year limitation period for FTC carryback when an NOL carryback from a subsequent year creates the excess FTC.
Additional guidance was provided by IRS regarding fax submissions of Form 1139 and Form 1045 filings just before the April 17 start date.
Funds holding distressed debt may consider whether accrual of interest income may be stopped under the ‘doubtful collectability’ exception.
Maintaining static conformity to the IRC, Wisconsin adopts several taxpayer-friendly provisions of the federal CARES Act.
Businesses seeking to increase cash flow should evaluate accelerating COVID-19 losses into 2019 federal income tax returns.
Industry groups are requesting clarification of the deadlines as extended by Notice 2020-23, which appears to offer a limited time frame.
Remote programming employee directly impacted an Arkansas employer's ability to carry out its mission and purpose.
Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.
Some individuals who took RMDs this year before they were waived by the CARES Act have more than 60 days to roll the RMDs back in.
Corporate taxpayers filing a consolidated return have an added layer of rules to navigate when carrying back a net operating loss.
In response to the COVID-19 pandemic, the IRS is encouraging taxpayers to fax – rather than mail – Form 1139 and Form 1045 filings.
Notice 2020-23 postpones the due date for Form 5500 (Annual Return/Report for Employer Plans) filings for some plans.
The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.
Notice 2020-23 provides corporate filers with guidance on extended filing and payment dates, with additional specifics and clarifications.
A foreign tax credit transaction that was previously referenced in Notice 2004-20 has been removed by the IRS.
IRS releases Notice 2020-23 which further expands COVID-19 filing and payment relief and revises the extension period.
The IRS provided long-awaited guidance for taxpayers anxious to take advantage of the NOL provisions in the CARES Act.
Recent guidance extends certain deadlines for LIHTC, WOTC, and Historic Rehabilitation tax credits because of COVID-19.
Notice 2020-23 incorporates Rev. Proc. 2018-58 filing postponements to extend certain excise tax filing deadlines.
Recent guidance provides that certain deadlines, including the allowable time to invest in a QOF, are now extended because of COVID-19.
Investors looking to accelerate write-offs on investments should be aware of an obscure section 382 rule that could destroy the tax-shield.
The IRS issued Notice 2020-23 granting broad filing and payment relief to most taxpayers including individuals, estates and trusts.
The IRS issued guidance extending the time for taxpayers to file certain Form 3115s and Form 1128s to July 15, 2020.
Notice 2020-23 clarifies that most filing, payment and election obligations for S corporations and partnerships is postponed until July 15.
Notice 2020-23 extends deadlines for like-kind exchanges under section 1031 and involuntary conversion replacements under section 1033.
IRS announces new July 15, 2020 deadline for Americans living abroad, nonresident aliens, and foreign corporations.
California-based employers have limited window to submit requests for cash grants from COVID-19 related employee training program.
The bills address the state's IRC conformity as it relates to new federal section 163(j) limitation rules, among other provisions.
As businesses renegotiate debts in the aftermath of COVID-19, it is critical to understand whether the debt is considered publicly traded.
Technology investments in response to the COVID-19 outbreak may be eligible for the research and development tax credit.
Motivated by the tax relief provisions of the CARES Act, the IRS is allowing all partnerships to file 2018 and 2019 amended returns.
Three recent cost of goods sold cases represent the highly nuanced nature of the Texas franchise tax calculation.
Employer social security payroll tax payment deferral for taxes incurred from March 27th through Dec. 31, 2020.
The IRS recently issued 66 FAQs addressing payroll tax credits for COVID-19-related paid family and sick leave.
The Department of Labor has issued updated questions and answers regarding paid leave for employees impacted by COVID-19.
Accelerating worthless stock deductions on an insolvent subsidiary without disposing of the business to increase NOL carrybacks.
Delaware notices advise companies to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
SBA issues interim final PPP guidance for lenders and borrowers at 6:47pm day before loan program is set to begin.
The CARES Act provides business and tax relief to portfolio companies and investors. However, affiliation rules could limit SBA loan relief.
Basic questions answered to help taxpayers interpret and claim the Employee Retention Tax Credit of the CARES Act.
Before filing NOL carryback claims it is important to understand whether a previous M&A transaction impacts who benefits from the refund.
IRS grants limited penalty relief for failure to deposit and pay employment taxes pursuant to the Families First Act and CARES Act.
Examples of tax-free payments under section 139 that employers may provide employee affected by the COVID-19 pandemic.
Immediate and retroactive expensing of qualified improvement property creates tax saving opportunities for taxpayers.
Employers should review retirement plan provisions for employee assistance and cash saving opportunities in response to economic conditions.
Because of COVID-19 concerns, the IRS is extending pending deadlines for employers to adopt updated 403(b) retirement plan documents.
IRS to temporarily accept scanned or digital signatures and will electronically share certain documents via Email.
The IRS has moved the due date for adopting IRS preapproved pension plan document from to April 30, 2020 to July 31, 2020.
The CARES Act provides broad support and relief for tax-exempt organizations affected by the coronavirus pandemic.
The IRS issued guidance permitting an automatic extension for gift and GST tax filings and payments until July 15th
Act contains broad relief for individuals and businesses; includes funding vehicles, recovery payments, and modifications to TCJA provisions
Companies should reflect the changes in tax law under the CARES Act in the period of enactment for financial statements.
Today, the House of Representatives passed the CARES Act on a voice vote and the President signed the bill enacting it into law.
The LB&I Division of the IRS announced that it would suspend the enforcement of information requests sent during audits.
CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships
Mandatory paid leave for employees impacted by COVID-19 is set to start April 1, 2020, per new Department of Labor guidance.
As part of the COVID-19 effort, IRS temporarily adjusts and suspends key compliance program April 1, 2020- July 15, 2020
IRS is increasing its enforcement efforts relating to micro-captive transactions and providing guidance on how to remove benefits claimed.
Coronavirus Aid, Relief and Economic Security Act provides liquidity by providing five-year NOL carryback and other help for corporations.
The IRS has provided guidance to frequently asked questions related to Notice 2020-18 through 24 questions and answers published on IRS.gov.
Extensions for tax returns and payments due to the Coronavirus pandemic are largely inapplicable for most exempt organizations.
The IRS has implemented staff reductions and closed taxpayer assistance centers, which could affect mission-critical operations.
Federal income tax filing and payment relief extension to July 15, 2020 may not apply to all state income tax filings.
The IRS issued Notice 2020-18 which supersedes Notice 2020-17 and provides income tax filing and payment relief to affected taxpayers.
Cayman Islands has extended the deadline for filing 2019 FATCA and CRS reports to September 2020 and intends to launch a new portal.
On March 19, the U.S. Senate released the third round of emergency assistance resulting from the 2020 COVID-19 pandemic.
Limited sales and use tax filing and payment relief has been included in some of the state and local COVID-19 response guidance.
IRS LB&I issued a memo to communicate the process to centralize compliance risk determinations for research credit cases.
Discussion of how tax-exempt organizations can provide assistance to those impacted by the coronavirus pandemic.
The IRS issued Notice 2020-17 to provide guidance to taxpayers regarding extended tax payment deadlines due to the Coronavirus pandemic
Congress passes the Families First Coronavirus Response Act that mandates paid leave for employees impacted by COVID-19.
A taxpayer was assessed willful failure to file FBAR penalties after voluntarily withdrawing from OVDP program.
Congress, the White House and Treasury have taken action to assist businesses and individuals cope with business issues.
IRS determines that high deductible health plans can pay for testing and treatment of the coronavirus without tax consequences.
Rev. Proc. 2020-17 grants information reporting and penalty relief to individuals with respect to applicable tax-favored foreign trusts
The IRS recently released a PLR allowing a section 355 tax-free distribution, despite no revenue in the spun-off subsidiary’s business.
Altera petitions the Supreme Court of the United States to hear case regarding validity of cost sharing arrangement regulations.
New proposed regulations provide helpful examples of business entertainment and meals deductions still permissible after TCJA restrictions.
IRS LB&I announce campaigns to improve compliance with fuel mixture credits and research issues related to sections 41 and 174.
Guidance provides clarity to current and former small business farmers on procedural options for exemption from UNICAP for certain plants.
IRS issued guidance describing the start of construction requirement and partnership structure for the carbon sequestration credit.
Department issued compliance alert explains the sales and use tax collection responsibilities for marketplace facilitators and sellers.
Last year’s service-based and advanced computing business surcharges receive significant makeover after public concern.
Online software products allowing remote access to a host computer as well as screen sharing capabilities were taxable.
Discusses recent case that Mail box rule applies to statute of limitation when late filed return is also a claim for refund.
The IRS released the electronic Form 1023 and guidance for mandatory use of the online application, effective February 1, 2020
Six weeks after enacting significant tax changes, the Utah legislature and governor repealed the entire tax reform package.
Listed Transaction Penalty and Trust Fund Recovery Penalty (TFRP) require Supervisor Approval under I.R.C. Section 6751(b)
IRS has issued final regulations narrowing nonrecognition treatment for certain transfers of property to partnerships with foreign partners.
Ruling expresses IRS’ views in areas where regulations are silent; reinforces the need for transaction cost analysis.
Corporate income tax regulations provide procedures for pass-through entities to elect to be taxed as C corporations.
The IRS is willing to consider relief from double taxation resulting from the application of section 965 in limited circumstances.
The IRS describes the procedures required to make a one-time claim for all 2018 and 2019 biodiesel and alternative fuels tax credits.
The medical device excise tax, the health insurance tax and Cadillac tax have all been repealed by recent legislation.
New Jersey becomes the sixth state to adopt an entity-level tax establishing a workaround to the federal SALT deduction limitation.
Transition rules for proposed built-in gain regulations helpful, but do they signal impending finalization of anti-taxpayer rules?
Recent U.S. Tax Court cases shed light on the requirement that the IRS must obtain written supervisory approval of certain penalties.
The due date for providing 2019 Forms 1095-B and 1095-C to individuals has been extended by the IRS from Jan. 31, 2020 to March 2, 2020.
Taxpayers with filing deadlines should carefully consult state taxing authority rules and regulations on timing filings.
Financial Accounting Standards Board releases accounting standards update 2019-12 (ASU 2019-12) relating to simplifying ASC 740.
The Ninth Circuit has confirmed a Tax Court decision that denied S corp shareholders basis for loans held by a related S corporation.
Massachusetts Department of Revenue issues final guidance on application of section 163(j) Interest Expense Limitation.
The IRS finalized rules for withholding and reporting U.S. source payments to foreign individuals and financial institutions.
The IRS issued a notice of proposed rulemaking to provide guidance on procedures for recovery of a misdirected direct deposit refund.
The ruling allows taxpayers to amend a return to increase their ITC because of an increase in the basis of self-constructed property.
The Texas Comptroller adopted a $500,000 economic nexus threshold for the state's franchise tax effective in 2020.
The comment letter explains that certain S corporations that experienced an ownership change should also qualify under these rules.
Both incentive programs were scheduled to sunset in 2019; receive a one-year extension under federal tax bill.
House bill, if enacted, would increase SALT deduction cap in 2019 for certain taxpayers and repeal SALT deduction cap for 2020 and 2021
The SECURE Act makes changes affecting retirement benefits in qualified plans and in IRAs for both the employers and individuals.
The Act’s significant implications for individuals’ retirement and estate planning suggests that they consult with their advisors…now
The final Qualified Opportunity Zone regulations include several taxpayer favorable improvements over the proposed regulations.
Congress has repealed the Affordable Care Act’s Cadillac tax on employer health plans prior to its effective date in 2022.
Taxpayers received a pre-holiday surprise when Congress ended stalemate to agree to extend many popular tax incentives.
New legislation includes repeal of the parking tax on exempt organizations and streamlines the excise tax rate on net investment income.
The IRS has released the final version of Form W-4 reflecting changes to employee withholding from the Tax Cuts and Jobs Act.
The IRS released proposed regulations which supplant and largely following previous guidance in Notice 2018-68 with important distinctions.
The Internal Revenue Service recently announced planned implementation dates for mandatory e-filing by tax-exempt organizations.
IRS guidance establishes amendment deadline for 401(k) and other retirement plans to comply with new hardship distribution rules.
Delay in required reporting of tax basis capital may be less beneficial than it appears; many will still need to compute for 2019.
IRS issues guidance on voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs).
The IRS finalized Forms 8985 and 8986, a mechanism for partnerships to push-out partnership audit and AAR adjustments to their partners.
Final regulations on new sales and use tax registration and collection requirements address remote retailers and marketplace facilitators.
The Final QOZ Regulations have been submitted to the Office of Management and Budget for final review and publication is expected soon.
Newly released foreign tax credit regulations address tax reform changes, clarify existing rules and provide new elections and safe harbors.
IRS confirms that gifts between 2018 and 2025 will be covered by the exemption then in place and not in the year of death.
Ruling explores the difference between a capital contribution and a deductible payment on behalf of a corporate subsidiary.
After years of litigation, a state appellate court again declared Pennsylvania’s flat dollar cap for net loss carryover unconstitutional.
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.
The IRS released Revenue Procedure 2019-44 listing the inflation adjustments for individual, trust and estates.
New IRS enforcement campaign targeting the section 965 transition tax compliance indicates a likely increase in section 965 audit activity.
The IRS announced that syndicated conservation easements are a priority compliance area and it will increase enforcement efforts.
New law for sourcing sales of services and intangibles effective with tax years beginning on or after Jan. 1, 2020.
North Carolina joins more than 30 states adopting a marketplace facilitator nexus provision effective Feb. 1, 2020.
The IRS issues proposed regulations to update the life expectancy tables to reflect current, longer life expectancy rates.
Revenue Procedure 2019-43 supersedes Rev. Proc. 2018-31, providing procedures to change accounting methods with automatic consent.
The IRS publishes applicable annual limitations and maximums for retirement plans, resulting in small increases for 2020.
New guidance from the UK’s Her Majesty’s Revenue and Customs provides more clarity for businesses engaged digital asset businesses.
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.
All companies seeking QI, WP, or WT status for 2019 must apply by Nov. 15, 2019 to have an agreement in effect.
The IRS has published a long-awaited practice unit as guidance for examinations of electronic books and records under section 1441.
IRS denied a formal refund claim as untimely, but taxpayer obtained relief through the informal claim doctrine.
Joint LB&I and SB/SE directive allows taxpayers to claim work opportunity tax credit in the year delayed state certifications received.
The Massachusetts Department of Revenue establishes a $500,000 threshold for state corporate excise tax nexus.
Target company’s deduction claim denied because investment banking firm did not provide services to Target or for Target’s benefit.
There are numerous ways that an S corporation can compromise its status. Being careless with election forms is just one example.
The U.S. Treasury Dept. and the IRS released the 2019-2020 priority guidance plan, including items related to exempt organizations.
The IRS has finalized rules for bottom-dollar guarantees under the disguised sale rules and for partnership liability allocations generally.
New IRS cryptocurrency guidance provides much needed clarity but may require changes to returns not yet filed.
Supreme court will not hear case arguing that taxpayers can exclude the fuel tax credit from income and also deduct the tax as an expense.
Court found corporation did not have reasonable cause and good faith for its understatement of tax in upholding a negligence penalty.
Proposed rules limit the impact and reduce the reporting burden caused by tax reform changes to CFC ownership rules.
Recently released draft 2019 Schedule K-1s showcase a major shift in reporting that may begin with the next filing season.
Pennsylvania Department of Revenue issues guidance that administratively implements economic nexus for corporate net income tax.
Wisconsin published final regulations on corporate income tax nexus. The new regulations establish 15 day activity threshold.
A court found that conclusory statements without additional evidence were insufficient to support an R&D credit study.
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 issued Rev. Proc. 2019-39, a revenue procedure that establishes a system of recurring remedial amendment periods.
Appeals court finds Taxpayer did not have reasonable cause for claiming fuel tax credits and is subject to 200% penalty.
Proposed regulations reflect updated donor and other information reporting requirements; related penalty relief provided.
IRS has finalized safe harbor provisions that rental real estate enterprises may use to qualify as a trade or business for section 199A.
The IRS issued final regulations on the 401(k) plan hardship distribution requirements as amended by tax reform (T.D. 9875).
Proposal would clarify how the bonus depreciation related party rules and no prior use rules apply in the context of consolidated returns.
Final bonus depreciation rules similar to previously proposed rules, uncertainty remains for certain transactions.
The IRS announced new relief procedures from paying back taxes for certain former citizens who wish to become compliant.
State enacts “ABC test” for determining when employees are considered independent contractors; prior test still used for some industries.
Final and re-proposed regulations released by the Treasury and IRS address important factors for 100% bonus depreciation.
The announcement states that select taxpayers qualify for a settlement offer for abusive micro-captive insurance transactions.
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
Arizona Supreme Court finds online travel companies must collect tax on service fees and mark-ups paid to book hotel rooms.
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.
Department of Revenue Services releases guidance addressing increased sales and use tax rate for certain digital goods and services.
TIGTA General Business Credit Review suggests changes to R&D Credit Exams after identifying billions of Carryforward Claim discrepancies.
CDFI Fund opens final round of allocation before program is scheduled to expire; extension efforts underway in Congress.
A favorable ruling on a "fit and focus" spin-off reiterates that only a minimal amount of employee overlap is permissible.
Fluctuation in value of stock did not impact exception to gain recognition, but no ruling on overall tax-free nature of reorganization.
Beginning in 2020, some individual taxpayers working remotely in Illinois will have a 30-day safe harbor from the state income tax.
IRS issues proposed regulations regarding special valuation rules for employee’s personal use of an employer-provided vehicle.
Court dismisses a tax refund suit for lack of jurisdiction, though postmarked before the statute of limitations expired.
New Jersey Division of Taxation rescinds unpopular GILTI and FDII allocation guidance issued in December; new guidance expected shortly.
IRS Chief Counsel opined that Target’s consolidated group survived notwithstanding the explicit language of the reverse acquisition rules.
IRS answers a few important questions regarding the taxation and withholding rules for uncashed distribution checks.
Proposed regulations provide guidance on classifying cloud transactions and income sourcing for transfers of digital content.
As of Aug. 16, 2019, the Taxpayer First Act modifies the notification rules when contacting third parties and limits John Doe summonses.
Cost-sharing arrangements remain in flux as Altera continues. Taxpayers should monitor the developments to ensure appropriate alignment.
Rev. Proc. 2019-34 offers simplified procedures for insurers to change accounting methods to comply with section 807 for reserves.
In PLR 201930011, the Service rules that it is OK to “go your own way” without tax penalty in a textbook split-up.
The state has indicated that it will enforce economic sales tax nexus on Oct. 1, 2019, without a minimum sales or transaction threshold.
Revenue Procedure 2019-33 provides procedures for taxpayers to make or revoke certain bonus depreciation elections.
Actual extension not required to supersede timely filed return, avoiding new adjustment procedures, by extended return deadline.
The IRS has begun sending over 10,000 letters to certain taxpayers advising them to report virtual currency transactions.
The IRS released final regulations that address income inclusion when a lessor elects to treat the lessee as having acquired the ITC.
The District enacts emergency legislation implementing the FY20 budget and modifying incentives for qualified high technology companies.
New guidance provides automatic method changes for insurance companies to comply with section 846 and revises unpaid loss discount factors.
The IRS LB&I Division has recently announced that it is adding six new compliance campaigns to its growing list of campaigns.
A recent court case shows the IRS’s power to penalize the failure to disclose a transaction substantially similar to a listed transaction.
A recent GASB Exposure Draft addresses the accounting for Internal Revenue Code Section 457 deferred compensation plans.
New IRS guidance allows high deductible health plans to pay for treatments for chronic health conditions as preventive care.
Taxpayer must use the year-by-year method in determining NOL carryover due to section 170 adjustments to modified taxable income.
Final regulations terminate Reg. Section 1.451-5, which previously allowed multiyear deferral of advance payments for goods and services.
Hawaii becomes the first state to adopt a $100,000 sales or 200 transaction threshold applicable to the state’s income tax.