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Archive for January 20th, 2020

sgrgas

IRS Releases Final and Proposed BEAT Regulations

IRS Releases Final and Proposed BEAT Regulations The IRS has issued final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A. The BEAT is a minimum tax that certain large corporations must pay on certain payments made to foreign related parties, and was added by the Tax Cuts and […]

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wnaegele

Final and Proposed Regulations Address Foreign Tax Credit

Final and Proposed Regulations Address Foreign Tax Credit The IRS has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain the basic approach and structure of the 2018 proposed regulations ( NPRM REG-105600-18). […]

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ttasch

Partner Tax Basis Capital Reporting Not Required Until 2020 Partnership Tax Years

Partner Tax Basis Capital Reporting Not Required Until 2020 Partnership Tax Years The IRS has released guidance that provides that the requirement to report partners’ shares of partnership capital on the tax basis method will not be effective for 2019 partnership tax years, but will first apply to 2020 partnership tax years. 2019 Reporting For […]

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tzanata

Final Regulations on Calculation of UBTI Issued

Final Regulations on Calculation of UBTI Issued The IRS has released final regulations that present guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI) under Code Sec. 512(a). Background Organizations that are otherwise exempt from tax under Code Sec. 501(a) are subject to tax on their unrelated business […]

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