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Author Archive for Elias Koumniotes

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ekoumniotes

Proposed Rules Clarifying Carried Interest Limitation Expected Early 2020, Kautter Says

Proposed Rules Clarifying Carried Interest Limitation Expected Early 2020, Kautter Says Treasury and the IRS are expected to release proposed rules in “early 2020” that would clarify certain limitations on the carried interest tax break, according to David Kautter, Treasury’s assistant secretary for tax policy. Kautter briefly addressed the proposed regulations’ timeline while speaking at […]

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ekoumniotes

Eligible Partnerships Granted Extension to File Form 1065 and Schedules K-1

Eligible Partnerships Granted Extension to File Form 1065 and Schedules K-1 The IRS has granted a six-month extension to eligible partnerships to file a superseding Form 1065, U.S. Return of Partnership Income, and furnish corresponding Schedules K-1, Partner’s Share of Income, Deductions, Credits. For a calendar year partnership, the deadline to file Form 1065 and […]

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ekoumniotes

Final Rules Limit Charitable Contributions Made for SALT Credits

Final Rules Limit Charitable Contributions Made for SALT Credits The IRS has issued final regulations that require taxpayers to reduce the amount any charitable contribution deduction by the amount of any state and local tax (SALT) credit they receive or expect to receive in return. The rules are aimed at preventing taxpayers from getting around […]

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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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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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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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