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Author Archive for Donald Sager

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Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill “A thumb goes up, a car goes by…” Tax extenders remain a top contender for “hitching a ride” on November’s must-pass government funding bill. Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in […]

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dsager

Cryptocurrency Guidance, Virtual Currency FAQs Released

Cryptocurrency Guidance, Virtual Currency FAQs Released The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance: a taxpayer does not have gross income from a “hard fork” of the taxpayer’s cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; and a taxpayer has ordinary […]

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dsager

SALT Cap Not Unconstitutionally Coercive

SALT Cap Not Unconstitutionally Coercive A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive. In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the […]

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dsager

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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dsager

Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed Regs Address Tax Implications of LIBOR Elimination Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements. On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be […]

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dsager

Continuity Safe Harbor Deadlines for Energy Credit Facility Construction May Be Tolled for National Security Delays

Continuity Safe Harbor Deadlines for Energy Credit Facility Construction May Be Tolled for National Security Delays The continuity safe harbor placed-in-service date deadlines for the investment tax energy credit (Code Sec. 48) and the renewable electricity production credit (Code Sec. 45(a)) may be tolled if a construction delay is caused by national security concerns raised […]

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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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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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dsager

Proposed Regs Address Foreign Tax Credit Changes

Proposed Regs Address Foreign Tax Credit Changes Highly anticipated foreign tax credit regulations have been issued that provide guidance on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act ( P.L. 115-97). The proposed regulations address: allocation and apportionment of the deductions under Code Secs. 861 through […]

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