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Archive for May 16th, 2019

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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apresti

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties The Senate’s top Democratic tax writer is calling on the IRS and Treasury to further waive underpayment penalties for the 2018 tax year. Nearly 30 million taxpayers are expected to have underpaid taxes last year, according to the Government Accountability Office (GAO). Underpayment Penalty […]

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ekoumniotes

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance New IRS guidance fills in several more pieces of the Code Sec. 199A passthrough deduction puzzle. Taxpayers can generally rely on all of these new final and proposed rules. Final Regulations The final regulations in T.D. 98xx_1 largely adopt the proposed regulations in NPRM REG-107892-18 (August 16, 2018), but […]

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dsager

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

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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lvarela

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments The IRS has issued proposed regulations on the information reporting requirements under Code Secs. 101(a)(3) and 6050Y, added by the Tax Cuts and Jobs Act ( P.L. 115-97). The regulations are to apply to reportable life insurance policy sales made, and reportable death benefits paid, after December […]

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lvarela

National Taxpayer Advocate Nina Olson Announces Retirement

National Taxpayer Advocate Nina Olson Announces Retirement Nina E. Olson, the National Taxpayer Advocate (NTA), has announced her decision to retire this summer from the esteemed NTA position at the IRS. Olson has served as taxpayers’ “voice” within the IRS and before Congress for the last 18 years. Olson will retire from the position of NTA on […]

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