Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception Proposed regulations provide rules on the attribution of ownership of stock or other interests for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The proposed […]

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest Highly anticipated proposed regulations have been issued on the withholding required with respect to the disposition of certain partnership interests. The proposed regulations affect certain foreign persons that recognize gain or loss on the disposition of an interest in a partnership that is […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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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Archive for June 13th, 2019

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses

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

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

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 2)

Bipartisan House Bill Aims to Fix “Retail Glitch”

House Approves Bipartisan IRS Reform Bill

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