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Author Archive for Andrew Presti

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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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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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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apresti

Practitioner’s Corner: Proposed Regs for Tax Reform’s Business Interest Limitation Expected Soon

Practitioner’s Corner: Proposed Regs for Tax Reform’s Business Interest Limitation Expected Soon The IRS is expected to soon release proposed regulations for tax reform’s new business interest limitation. “They are so broad that nearly every domestic taxpayer will be impacted,” Daniel G. Strickland, an associate at Eversheds Sutherland, told Wolters Kluwer. The first set of proposed regulations […]

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apresti

New look to TINs/EINs to prevent identity theft/refund fraud

New look to TINs/EINs to prevent identity theft/refund fraud The IRS continues to ramp-up its work to fight identity theft/refund fraud and recently announced new rules allowing the use of abbreviated (truncated) personal identification numbers and employer identification numbers. Instead of showing a taxpayer’s full Social Security number (SSN) or other identification number on certain […]

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apresti

House Approves IRS Reform Package

House Approves IRS Reform Package The House on April 18 approved the two largest bills of a bipartisan IRS reform package. On April 17, the House approved seven other bills, by voice vote, which are also part of the larger bipartisan package. Its aim is to restructure the IRS for the first time in 20 […]

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apresti

IRS Computer Glitch Extends 2017 Filing Deadline One Day

IRS Computer Glitch Extends 2017 Filing Deadline One Day The IRS provided an additional day for taxpayers to file and pay their taxes, following system issues that surfaced early on April 17. Individuals and businesses with a filing or payment due date of April 17 had until midnight on Wednesday, April 18, to file returns […]

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apresti

Treasury, OMB Agree to Increased Oversight of Tax Regulations

Treasury, OMB Agree to Increased Oversight of Tax Regulations Certain proposed regulations issued by Treasury will now be subject to additional oversight by the Office of Management and Budget (OMB). A Memorandum of Agreement (MOA) between Treasury and OMB released on April 12 specifies terms under which the Office of Information and Regulatory Affairs (OIRA) […]

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apresti

New Law Clarifies Partnership Audit Rules

New Law Clarifies Partnership Audit Rules Technical corrections to the partnership audit rules were included in the bipartisan Consolidated Appropriations Act (CAA), 2018 ( P.L. 115-141), which was signed by President Trump on March 23. The omnibus spending package, which provides funding for the government and federal agencies through September 30, contains several tax provisions, including […]

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