Nondiscrimination Relief for Closed Defined Benefit Plans Extended Again

Nondiscrimination Relief for Closed Defined Benefit Plans Extended Again The temporary nondiscrimination relief for closed defined benefit plans provided in Notice 2014-5, I.R.B. 2014-2, 276, is extended through plan years beginning in 2020. Notice 2014-5 provided temporary nondiscrimination relief for certain defined benefit pension plans that were “closed” before December 13, 2013. Notice 2014-5, I.R.B. 2014-2, 276, Notice 2015-28, I.R.B. 2015-14, 848, Notice […]

Final Regs Tweak Safe Harbor for Partnership Allocations of Creditable Foreign Tax Expenditures

Final Regs Tweak Safe Harbor for Partnership Allocations of Creditable Foreign Tax Expenditures The IRS has adopted final regulations with respect to the allocation by a partnership of foreign income taxes. The final regulations are intended to improve the operation of an existing safe harbor rule. This safe harbor rule, under Reg. §1.704-1(b)(4)(viii), determines whether allocations […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

Schedule Your Small Business Success Consultation

Author Archive for Lisa Varela

Nondiscrimination Relief for Closed Defined Benefit Plans Extended Again

Final Regs Tweak Safe Harbor for Partnership Allocations of Creditable Foreign Tax Expenditures

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info

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

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

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

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

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

Recent Posts

Archives

Contact Us

Newsletter

Our Locations

Subscribe to Receive Updates