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Archive for May 21st, 2019

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CFC Partners Required to Increase E&P for Subpart F Inclusions

CFC Partners Required to Increase E&P for Subpart F Inclusions The upper-tier controlled foreign corporation (CFC) partners of a domestic partnership were required to include in gross income their distributive share of income inclusions under subpart F from lower-tier CFCs, and increase earnings and profits (E&P) by the same amount. Regulations under Code Sec. 964provided preliminary […]

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tzanata

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

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tzanata

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

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tzanata

Bipartisan House Bill Aims to Fix “Retail Glitch”

Bipartisan House Bill Aims to Fix “Retail Glitch” A bipartisan House bill has been introduced that would fix a GOP tax law drafting error known as the “retail glitch.” The House bill, having over a dozen co-sponsors, is a companion measure to a bipartisan Senate bill introduced in March. Immediate Expensing The Restoring Investment in Improvements Act […]

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aaguanno

House Approves Bipartisan IRS Reform Bill

House Approves Bipartisan IRS Reform Bill The House on April 9 approved by voice vote a bipartisan, bicameral IRS reform bill. The IRS bill, which now heads to the Senate, would redesign the IRS for the first time in over 20 years. IRS Reform The Taxpayer First Act of 2019 (HR 1957), as amended, cleared […]

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wnaegele

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses Proposed regulations address gains that may be deferred when taxpayers invest in a qualified opportunity fund (QOF). Taxpayers may generally rely on these new proposed regulations. The IRS has also requested comments. The proposed regulations also withdraw and replace placeholder provisions in an earlier set […]

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tzanata

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams The IRS has provided a safe harbor for professional sports teams to avoid the recognition of gain or loss when trading players and/or draft picks. Under the safe harbor provision, the traded player’s contract or the traded draft pick would have […]

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