Ideas & Insights

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.

New Jersey Division of Taxation rescinds unpopular GILTI and FDII allocation guidance issued in December; new guidance expected shortly.

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 new pass-through entity level tax may benefit some individuals subject to the $10,000 SALT deduction limitation.

Revisions to the U.S. income tax treaties with Switzerland, Luxembourg, Japan and Spain may pass the Senate after years of being stalled.

New York enacts legislation exempting 95% of GILTI and increases the sales component of the economic sales tax nexus threshold.

The proposed regulations clarify fixes addressing the “grain glitch” and specify information cooperatives must provide to their patrons.

The IRS FAQ states that 1231 gains invested in a QOF before the second set of proposed regulations can still be eligible for gain deferral.

The Senate recently passed the Taxpayer First Act after eliminating the controversial Free File Program from the bill.

Minnesota’s long-awaited conformity bill presents new challenges for individual and corporate taxpayers; remote seller provisions modified.

Withholding generally applies to transfers of partnership interests by foreign persons, regulations generally follow previous guidance.

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.

The new Qualified Opportunity Zone regulations answer many questions that favor taxpayers, though some questions remain.

The reduced corporate tax rate enables a pass through entity to increase net R&D credit benefit by making a section 280C(c)(3) election.

The IRS released Rev. Rul. 2019-11 regarding the tax treatment of state and local tax refunds.