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Archive for January 18th, 2019

dsager

Proposed Regs Address Foreign Tax Credit Changes

Proposed Regs Address Foreign Tax Credit Changes Highly anticipated foreign tax credit regulations have been issued that provide guidance on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act ( P.L. 115-97). The proposed regulations address: allocation and apportionment of the deductions under Code Secs. 861 through […]

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sgrgas

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations are in response to changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), […]

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sgrgas

Proposed Regs Provided for Code Sec. 163(j) Limit

Proposed Regs Provided for Code Sec. 163(j) Limit The IRS has proposed regulations on the limitation on the business interest expense deduction under Code Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The IRS also has issued a safe harbor that allows taxpayers to treat certain infrastructure trades […]

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tzanata

2019 Standard Mileage Rates Released

2019 Standard Mileage Rates Released The IRS released the optional standard mileage rates for 2019. Most taxpayers may use these rates to compute deductible costs of operating vehicles for: business, medical, and charitable purposes. Some members of the military may also use these rates to compute their moving expense deductions. 2019 Standard Mileage Rates The […]

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sgrgas

Deductions Denied to Medical Marijuana Dispensary

Deductions Denied to Medical Marijuana Dispensary A nonprofit corporation that operated a medical-marijuana dispensary legally under California law was not allowed to claim deductions for business expenses on its federal return. Code Sec. 280E, which prevents any trade or business that consists of trafficking in controlled substances from deducting any business expenses, applied. Meaning of […]

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sgrgas

Guidance Issued on Nondeductible Portion of Parking Fringe Expenses and UBTI

Guidance Issued on Nondeductible Portion of Parking Fringe Expenses and UBTI The IRS has provided guidance and examples for calculating the nondeductible portion of parking expenses. In addition, the IRS has provided guidance to tax-exempt organizations to help such organizations determine how unrelated business taxable income (UBTI) will be increased by the nondeductible amount of […]

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lvarela

Guidance on Tax Benefit for Stock Options and Restricted Stock Units

Guidance on Tax Benefit for Stock Options and Restricted Stock Units The IRS has released initial guidance on the new Code Sec. 83(i), added by the 2017 Tax Cuts and Jobs Act ( P.L. 115-97). Code Sec. 83 generally provides for the federal income tax treatment of property transferred in connection with the performance of […]

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sgrgas

Proposed Regulations Provide Guidance on Base Erosion and Anti-Abuse Tax (BEAT)

Proposed Regulations Provide Guidance on Base Erosion and Anti-Abuse Tax (BEAT) Proposed regulations provide much anticipated guidance on the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A and related reporting requirements. The regulations are proposed to apply generally to tax years beginning after December 31, 2017, but taxpayers may rely on these proposed […]

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sgrgas

Accounting Method Procedures Simplified for Complying with AFS Deadline for All Events Test

Accounting Method Procedures Simplified for Complying with AFS Deadline for All Events Test The IRS will grant automatic consent to accounting method changes to comply with new Code Sec. 451(b), as added by the Tax Cuts and Jobs Act ( P.L. 115-97). In addition, some taxpayers may make the accounting method change on their tax […]

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