Ideas & Insights

Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.

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.

Learn why the IRS is increasing its scrutiny on high net worth athletes and entertainers, and what can be done before an audit.

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.

The CARES Act enacted a temporary suspension of the TCJA’s 80% limitation on the use of NOLs, this will impact FTC and ODL calculations.

Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.

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

State tax increases in various forms seem inevitable because of massive budget shortfalls caused by the pandemic and economic crisis.

IRS releases final and proposed regulations on the deduction for dividends from foreign corporations and related reporting rules.

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.

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