United States
Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.
New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.
In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.
Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.
The IRS released final regulations affecting S corporations that revoked their status in response to TCJA and lower C corporation tax rates.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
Notice 2020-23 clarifies that most filing, payment and election obligations for S corporations and partnerships is postponed until July 15.
CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships
IRS to issue guidance aimed at providing relief for S corporations that might have jeopardized their S status.
Tax Court concludes that use of intermediary company prevented shareholders from utilizing debt to claim pass-through losses.
The IRS will begin sending letters to S corporation shareholders who claimed flow-through losses as soon as late October.
The tax court concluded that constructive ownership rules cause deductions to be deferred until participant includes amount in income.
The IRS ruled that disproportionate distributions resulting from incorrect ownership information did not terminate subchapter S status.