Ideas & Insights

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.

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.

Final carried interest regulations ease rules for capital interest allocations as well as related party transfers.

New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.

The regulations largely mirror the proposed regulations with additional, mostly favorable, clarifications for taxpayers.

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.

New regulations under section 4968 provide favorable guidance to private colleges and universities subject to the excise tax.

The final regulations address the treatment of administration expenses and excess deductions on termination of an estate or trust.

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.

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.