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Archive for July 12th, 2019

tzanata

Final and Proposed Regs on GILTI-Related Matters

Final and Proposed Regs on GILTI-Related Matters Final regulations address the global intangible low-taxed income (GILTI) provisions of Code Sec. 951A. The final regulations retain the basic approach and structure of the proposed regulations published on October 10, 2018. The final regulations address open questions and comments received on the proposed regulations. Final regulations on the […]

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tzanata

Proposed Rules Explain 199A Deduction for Cooperatives and Patrons

Proposed Rules Explain 199A Deduction for Cooperatives and Patrons Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons: Proposed regulations provide detailed rules for coop patrons and specified cooperatives to calculate the deduction. A proposed revenue procedure provides three methods for specified cooperatives to […]

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apresti

Employers Can Offer HRAs Integrated with Individual Coverage

Employers Can Offer HRAs Integrated with Individual Coverage Final rules allow employers to use health reimbursement arrangements (HRAs) to reimburse employees for the purchase individual insurance coverage, including coverage on an Affordable Care Act Exchange. The rules also allow “excepted benefit HRAs,” which would not have to be integrated with any coverage. The rules generally apply for […]

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ekoumniotes

Final Rules Limit Charitable Contributions Made for SALT Credits

Final Rules Limit Charitable Contributions Made for SALT Credits The IRS has issued final regulations that require taxpayers to reduce the amount any charitable contribution deduction by the amount of any state and local tax (SALT) credit they receive or expect to receive in return. The rules are aimed at preventing taxpayers from getting around […]

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bwhelan

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon Senate tax writers on Capitol Hill continue to discuss bipartisan retirement savings bills as the House gears up for a vote on a related tax measure. The Senate Finance Committee (SFC) held a May 14 hearing during which lawmakers on both sides […]

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dsager

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized Final regulations relating to the low-income housing tax credit revise and clarify requirements that low-income housing agencies must follow when conducting physical inspections of low-income units and reviewing low-income certifications and other documentation. The regulations finalize previously issued temporary regulations (T.D. 9753, February 25, 2016). Sample […]

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lvarela

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info The IRS has corrected Notice 2019-20, which provided a waiver of penalties under Code Secs. 6722(failure to furnish correct payee statements) and 6698 (failure to file partnership return) for certain partnerships that file and furnish Schedules K-1 to Form 1065 without reporting negative tax basis capital account […]

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lvarela

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss Final regulations have been issued on transactions of U.S. taxpayers that have qualified business units (QBUs) with functional currency other than the U.S. dollar. Specifically, the final regulations: cover combinations and separations of QBUs subject to Code Sec. 987 (Reg. 1.987-2 […]

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sgrgas

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income Medicaid waiver payments were earned income, even though IRS Notice 2014-7 treated them as “difficulty of care” foster care payments that were excluded from gross income. The Tax Court held that excluding the payments from earned income would improperly deny the […]

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