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Author Archive for Lisa Varela

lvarela

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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lvarela

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss Final regulations have been issued on transactions of U.S. taxpayers that have qualified business units (QBUs) with functional currency other than the U.S. dollar. Specifically, the final regulations: cover combinations and separations of QBUs subject to Code Sec. 987 (Reg. 1.987-2 […]

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lvarela

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception Proposed regulations provide rules on the attribution of ownership of stock or other interests for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The proposed […]

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lvarela

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest Highly anticipated proposed regulations have been issued on the withholding required with respect to the disposition of certain partnership interests. The proposed regulations affect certain foreign persons that recognize gain or loss on the disposition of an interest in a partnership that is […]

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lvarela

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon Senate tax writers on Capitol Hill continue to discuss bipartisan retirement savings bills as the House gears up for a vote on a related tax measure. The Senate Finance Committee (SFC) held a May 14 hearing during which lawmakers on both sides […]

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lvarela

CFC Partners Required to Increase E&P for Subpart F Inclusions

CFC Partners Required to Increase E&P for Subpart F Inclusions The upper-tier controlled foreign corporation (CFC) partners of a domestic partnership were required to include in gross income their distributive share of income inclusions under subpart F from lower-tier CFCs, and increase earnings and profits (E&P) by the same amount. Regulations under Code Sec. 964provided preliminary […]

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lvarela

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments The IRS has issued proposed regulations on the information reporting requirements under Code Secs. 101(a)(3) and 6050Y, added by the Tax Cuts and Jobs Act ( P.L. 115-97). The regulations are to apply to reportable life insurance policy sales made, and reportable death benefits paid, after December […]

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lvarela

National Taxpayer Advocate Nina Olson Announces Retirement

National Taxpayer Advocate Nina Olson Announces Retirement Nina E. Olson, the National Taxpayer Advocate (NTA), has announced her decision to retire this summer from the esteemed NTA position at the IRS. Olson has served as taxpayers’ “voice” within the IRS and before Congress for the last 18 years. Olson will retire from the position of NTA on […]

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