Ideas & Insights

The proposed regulations clarify rules on simplified accounting methods for qualified small business taxpayers.

Treasury proposes clean up to air trans excise tax regulations and rules to exempt payments by aircraft owners to management companies.

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 and proposed regulations related to the GILTI high tax exclusion and subpart F high tax exception released.

Final regulations allow any reasonable method to be applied in calculating deduction amounts allowed under sections 250, 172, and 163(j).

Treasury and the IRS have issued final regulations on determining the amount of the deduction for FDII and GILTI.

Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.

The proposed regulations provide long-awaited guidance for the disallowance of qualified transportation benefits and commuting expenses.

The new proposed regulations clarify what constitutes ‘real property’ for purposes of section 1031 to help implement changes in TCJA.

Section 4960 proposed rules add examples and clarity while generally following interim guidance and providing taxpayer-friendly exceptions.

Exempt organizations may carryback siloed NOLs to tax years beginning before 2018 and apply them to net unrelated business income.

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.

Deferral of the $500,000 business loss limitation may create immediate complications for 2018 and 2019 tax returns.

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.

New proposed regulations provide helpful examples of business entertainment and meals deductions still permissible after TCJA restrictions.