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Archive for September 12th, 2019

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lvarela

Eligible Partnerships Granted Extension to File Form 1065 and Schedules K-1

Eligible Partnerships Granted Extension to File Form 1065 and Schedules K-1 The IRS has granted a six-month extension to eligible partnerships to file a superseding Form 1065, U.S. Return of Partnership Income, and furnish corresponding Schedules K-1, Partner’s Share of Income, Deductions, Credits. For a calendar year partnership, the deadline to file Form 1065 and […]

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lvarela

Proposed Regulations Update Fleet-Average, Vehicle Cents-Per-Mile Valuation Rules

Proposed Regulations Update Fleet-Average, Vehicle Cents-Per-Mile Valuation Rules Proposed regulations increase a vehicle’s maximum value for eligibility to use the fleet-average valuation rule or the vehicle cents-per-mile valuation rule. The increase to $50,000 is effective for the 2018 calendar year. The maximum value is adjusted annually for inflation after 2018. The proposed regulations provide transition […]

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lvarela

Nondiscrimination Relief for Closed Defined Benefit Plans Extended Again

Nondiscrimination Relief for Closed Defined Benefit Plans Extended Again The temporary nondiscrimination relief for closed defined benefit plans provided in Notice 2014-5, I.R.B. 2014-2, 276, is extended through plan years beginning in 2020. Notice 2014-5 provided temporary nondiscrimination relief for certain defined benefit pension plans that were “closed” before December 13, 2013. Notice 2014-5, I.R.B. 2014-2, 276, Notice 2015-28, I.R.B. 2015-14, 848, Notice […]

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lvarela

Final Regs Tweak Safe Harbor for Partnership Allocations of Creditable Foreign Tax Expenditures

Final Regs Tweak Safe Harbor for Partnership Allocations of Creditable Foreign Tax Expenditures The IRS has adopted final regulations with respect to the allocation by a partnership of foreign income taxes. The final regulations are intended to improve the operation of an existing safe harbor rule. This safe harbor rule, under Reg. §1.704-1(b)(4)(viii), determines whether allocations […]

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apresti

Proposed Regulations Classify Cloud and Digital Content Transactions

Proposed Regulations Classify Cloud and Digital Content Transactions Transactions involving digital content and cloud computing have become common due to the growth of electronic commerce. The transactions must be classified in terms of character so that various provisions of the Code, such as the sourcing rules and subpart F, can be applied. Digital Content TransactionsExisting Reg. […]

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sgrgas

LB&I Withdraws Guidance on Cost-Sharing Arrangement Stock Based Compensation

LB&I Withdraws Guidance on Cost-Sharing Arrangement Stock Based Compensation The IRS Large Business and International Division (LB&I) has withdrawn its directive to examiners that provided instructions on transfer pricing issue selection related to stock based compensation (SBC) in cost sharing arrangements (CSAs). U.S. taxpayers that are cost sharing participants must include SBC as intangible development […]

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ttasch

Nashville group buys the Westin Tampa Bay on Rocky Point, plans long-term renovation

Nashville group buys the Westin Tampa Bay on Rocky Point, plans long-term renovation https://www.bizjournals.com/tampabay/news/2019/07/02/nashville-group-buys-the-westin-tampa-bay-on-rocky.html By Ashley Gurbal Kritzer  – Senior Reporter, Tampa Bay Business Journal Jul 2, 2019, 2:50pm EDT Westin Tampa Bay, a 16-story hotel on Tampa’s Rocky Point, has been sold to a group of Nashville investors. Castlerock Asset Management said Tuesday that it […]

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aaguanno

House Approves Bipartisan Repeal of ACA’s “Cadillac” Tax

House Approves Bipartisan Repeal of ACA’s “Cadillac” Tax The House has approved a bipartisan repeal of the Affordable Care Act’s (ACA) so-called “Cadillac”excise tax on certain high-cost insurance plans. ACA Cadillac Tax Repeal The Middle Class Health Benefits Tax Repeal Bill (HR 748) cleared the House on the evening of July 17 by a 419-to-6 vote. […]

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ttasch

Final Regulations Clarify Employment Tax Treatment of Partners in Partnership That Owns Disregarded Entity

Final Regulations Clarify Employment Tax Treatment of Partners in Partnership That Owns Disregarded Entity The IRS has released final regulations that clarify the employment tax treatment of partners in a partnership that owns a disregarded entity. The Treasury Department and the IRS had issued the temporary regulations ( T.D. 9766) to clarify that the rule that […]

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