Ideas & Insights

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.

Regulations would implement law requiring gains on the sale of some partnership interests to be treated as connected with a US business.

JCT summary of law differs from Treasury guidance regarding pass-through of DPAD from fiscal year entity to owner in 2018.

New proposed regulations implement sections 245A(e) and 267A regarding hybrid dividends and transactions with hybrid entities.

The IRS and Treasury have recently released proposed regulations regarding the new Base Erosion and Anti-Abuse Tax (BEAT).

A new LB&I directive provides guidance on how to risk assess DPAD claims and when to assess an erroneous claim for refund credit penalty.

Rate reduction triggered after revenue metrics achieved; draft TCJA guidance published addressing the personal income tax.

Insurance companies seeking to make a change to the basis of computing certain reserves receive new automatic accounting method change.

Workaround aims to address the federal $10,000 SALT deduction cap; enacts economic nexus for out-of-state retailers.

The IRS has issued new FAQs for the 2018 tax year to provide guidance on filing and payment obligations under section 965.

The IRS provides guidance to assist in determining expenses for parking fringe benefits for purposes of section 274(a)(4) and 512(a)(7).

Notice 2018-97 provides needed year-end clarity on certain interpretive and administrative issues for the new deferral opportunity.

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.

The IRS has issued new FAQs to provide clarification and guidance for the filing of section 965 transfer agreements.

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.