Final Regs Define “Real Property” for Like-Kind Exchanges

Final Regs Define “Real Property” for Like-Kind Exchanges Final regulations clarify the definition of “real property” that qualifies for a like-kind exchange, including incidental personal property. Under the Tax Cuts and Jobs Act (TCJA, P.L. 115-97), like-kind exchanges occurring after 2017 are limited to real property used in a trade or business or for investment. The final regulations […]

Final Regs on Silo Rules for Calculating UBTI

Final Regs on Silo Rules for Calculating UBTI The IRS has issued final regulations with guidance on how a tax-exempt organization can determine whether it has more than one unrelated trade or business, how it should identify its separate trades and businesses, and how to separately calculate unrelated business taxable income (UBTI) for each trade […]

Final Regulations Address Transportation Fringe Benefits

Final Regulations Address Transportation Fringe Benefits The IRS has issued final regulations under Code Sec. 274 relating to the elimination of the employer deduction of for transportation and commuting fringe benefits by the Tax Cuts and Jobs Act ( P.L. 115-97), effective for amounts paid or incurred after December 31, 2017. The final regulations address the disallowance of […]

Final Regulations Coordinate Code Sec. 245A DRD Limit and GILTI Disqualified Basis Rule

Final Regulations Coordinate Code Sec. 245A DRD Limit and GILTI Disqualified Basis Rule Final regulations issued by the Treasury and IRS coordinate the extraordinary disposition rule that applies with respect to the Code Sec. 245A dividends received deduction and the disqualified basis rule under the Code Sec. 951A global intangible low-taxed income (GILTI) regime. Information reporting rules are also […]

IRS Extends Term of Gaming Industry Tip Compliance Agreement

IRS Extends Term of Gaming Industry Tip Compliance Agreement The IRS has modified Rev. Proc. 2007-32, I.R.B. 2007-22, 1322, to provide that the term of a Gaming Industry Tip Compliance Agreement (GITCA) is generally five years, and the renewal term of a GITCA is extended from three years to a term of up to five years. […]

IRS Proposes Regs on Centralized Partnership Audit Regime

IRS Proposes Regs on Centralized Partnership Audit Regime NPRM REG-123652-18 The IRS has issued proposed regulations for the centralized partnership audit regime that: clarify that a partnership with a QSub partner is not eligible to elect out of the centralized audit regime; add three new types of “special enforcement matters” and modify existing rules; modify […]

IRS Issues Final Regulations on Wage Withholding, Redesigned W-4

IRS Issues Final Regulations on Wage Withholding, Redesigned W-4 The IRS has issued final regulations that provide guidance for employers on federal income tax withholding from employees’ wages. The final regulations: address the amount of federal income tax that employers withhold from employees’ wages; implement changes made by the Tax Cuts and Jobs Act (TCJA) […]

Deadlines Extended for Qualified Opportunity Funds and Investors

Deadlines Extended for Qualified Opportunity Funds and Investors The IRS has announced various extensions of deadlines for qualified opportunity funds and their investors due to the Coronavirus pandemic. 180-Day Investment PeriodGenerally taxpayers must reinvestment capital gain in a qualified opportunity fund (QOF) within 180 days after the gain is realized from a sale or exchange. […]

Final Regulations Issued on FDII and GILTI Deduction

Final Regulations Issued on FDII and GILTI Deduction The Treasury and IRS have issued final regulations covering the Code Sec. 250 deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). Proposed regulations were issued on March 6, 2019 (NPRM REG-104464-18). The final regulations maintain the basic approach and structure of the proposed regulations and […]

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Author Archive for Lisa Varela

Final Regs Define “Real Property” for Like-Kind Exchanges

Final Regs on Silo Rules for Calculating UBTI

Final Regulations Address Transportation Fringe Benefits

Final Regulations Coordinate Code Sec. 245A DRD Limit and GILTI Disqualified Basis Rule

IRS Extends Term of Gaming Industry Tip Compliance Agreement

IRS Proposes Regs on Centralized Partnership Audit Regime

IRS Issues Final Regulations on Wage Withholding, Redesigned W-4

Deadlines Extended for Qualified Opportunity Funds and Investors

Final Regulations Issued on FDII and GILTI Deduction

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