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Archive for November 10th, 2019

dsager

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill “A thumb goes up, a car goes by…” Tax extenders remain a top contender for “hitching a ride” on November’s must-pass government funding bill. Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in […]

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lvarela

IRS Provides Section 199A Safe Harbor for Rental Real Estate

IRS Provides Section 199A Safe Harbor for Rental Real Estate The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to […]

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dsager

Cryptocurrency Guidance, Virtual Currency FAQs Released

Cryptocurrency Guidance, Virtual Currency FAQs Released The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance: a taxpayer does not have gross income from a “hard fork” of the taxpayer’s cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; and a taxpayer has ordinary […]

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dsager

SALT Cap Not Unconstitutionally Coercive

SALT Cap Not Unconstitutionally Coercive A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive. In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the […]

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dsager

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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dsager

Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed Regs Address Tax Implications of LIBOR Elimination Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements. On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be […]

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sgrgas

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final […]

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ttasch

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation Proposed regulations would provide guidance on the inclusion of income and deduction items in the calculation of built-in gains and losses under Code Sec. 382(h). The proposed regulations would: simplify the application of Code Sec. 382; provide more certainty to taxpayers in determining […]

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