Ideas & Insights

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

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

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

The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.

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.

Comments address concerns and recommendations regarding proposed regulations addressing section 382 built-in gains and losses.

IRS to retain regulations treating some related party debt as equity, but will propose rules easing one of the regulations’ harshest rules.

Final bonus depreciation rules similar to previously proposed rules, uncertainty remains for certain transactions.

Tax Court allows ordinary business bad debt deduction, rejecting argument that loans not secured by real property were nonbusiness loans.

Proposed regulations would accelerate credit card fee income and similar items, but would not affect most interest income items.

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.

Proposed rule would benefit certain purchasers of banks and other C corporations owning life insurance contracts.

Proposed regulations for section 250 deductions provide multi-step process to account for NOL deductions and interest deduction limitation.

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.