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Author Archive for Elias Koumniotes

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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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ekoumniotes

Interim Guidance for Excise Tax on Excess Remuneration and Parachute Payments

Interim Guidance for Excise Tax on Excess Remuneration and Parachute Payments The IRS has issued interim guidance on the excise tax payable by exempt organizations on remuneration in excess of $1 million and any excess parachute payments made to certain highly compensated current and former employees in the tax year. The excise tax imposed by Code […]

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ekoumniotes

Final Transition Tax Regulations Issued

Final Transition Tax Regulations Issued The Treasury and IRS have issued final regulations for determining the inclusion under Code Sec. 965 of a U.S. shareholder of a foreign corporation with post-1986 accumulated deferred foreign income. Code Sec. 965 imposes a “transition tax” on the inclusion. The final regulations retain the basic approach and structure of the proposed regulations, with certain changes. […]

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ekoumniotes

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures The IRS has issued its annual revisions to the general procedures for ruling requests, technical memoranda, determination letters, and user fees, as well as areas on which the Associate Chief Counsel offices will not rule. The revised procedures are generally effective January 2, […]

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ekoumniotes

AICPA, ABA Urge Extensive Changes to Proposed Transition Tax Rules

AICPA, ABA Urge Extensive Changes to Proposed Transition Tax Rules The American Institute of Certified Public Accountants (AICPA) and the American Bar Association (ABA) Section of Taxation are urging the IRS to make extensive changes to proposed “transition tax” rules. Transition Tax The Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), enacted last December, revived and amended Code […]

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ekoumniotes

Tax Reform Hurts Homeowners, House Democratic Report Says

Tax Reform Hurts Homeowners, House Democratic Report Says Homeowners will be hurt financially by last year’s tax reform, according to a new House Democratic staff report. The report alleges that real estate developers will primarily benefit from the new tax law at the expense of homeowners. The Democratic staff report was released by House Oversight […]

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ekoumniotes

Treasury Moves To Repeal 298 Unnecessary, Obsolete Regulations

Treasury Moves To Repeal 298 Unnecessary, Obsolete Regulations The Treasury Department has proposed repealing 298 regulations. According to the Treasury, the targeted rules are unnecessary, duplicative or obsolete. In addition, the Treasury proposed to amend another 79 regulations to reflect the repeal. Take away. “We continue our work to ensure that our tax regulatory system […]

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ekoumniotes

Year-end planning for capital gains and losses

Year-end planning for capital gains and losses As an economic incentive for individuals to save and invest, gains from the sale of capital assets held for at least one year unless offset by losses, as well qualified dividends received during the year, may be taxed at rates lower than ordinary income tax rates. The tax […]

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