LB&I Withdraws Guidance on Cost-Sharing Arrangement Stock Based Compensation

LB&I Withdraws Guidance on Cost-Sharing Arrangement Stock Based Compensation The IRS Large Business and International Division (LB&I) has withdrawn its directive to examiners that provided instructions on transfer pricing issue selection related to stock based compensation (SBC) in cost sharing arrangements (CSAs). U.S. taxpayers that are cost sharing participants must include SBC as intangible development […]

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income Medicaid waiver payments were earned income, even though IRS Notice 2014-7 treated them as “difficulty of care” foster care payments that were excluded from gross income. The Tax Court held that excluding the payments from earned income would improperly deny the […]

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties The Senate’s top Democratic tax writer is calling on the IRS and Treasury to further waive underpayment penalties for the 2018 tax year. Nearly 30 million taxpayers are expected to have underpaid taxes last year, according to the Government Accountability Office (GAO). Underpayment Penalty […]

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations are in response to changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), […]

Proposed Regs Provided for Code Sec. 163(j) Limit

Proposed Regs Provided for Code Sec. 163(j) Limit The IRS has proposed regulations on the limitation on the business interest expense deduction under Code Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The IRS also has issued a safe harbor that allows taxpayers to treat certain infrastructure trades […]

Deductions Denied to Medical Marijuana Dispensary

Deductions Denied to Medical Marijuana Dispensary A nonprofit corporation that operated a medical-marijuana dispensary legally under California law was not allowed to claim deductions for business expenses on its federal return. Code Sec. 280E, which prevents any trade or business that consists of trafficking in controlled substances from deducting any business expenses, applied. Meaning of […]

Guidance Issued on Nondeductible Portion of Parking Fringe Expenses and UBTI

Guidance Issued on Nondeductible Portion of Parking Fringe Expenses and UBTI The IRS has provided guidance and examples for calculating the nondeductible portion of parking expenses. In addition, the IRS has provided guidance to tax-exempt organizations to help such organizations determine how unrelated business taxable income (UBTI) will be increased by the nondeductible amount of […]

Proposed Regulations Provide Guidance on Base Erosion and Anti-Abuse Tax (BEAT)

Proposed Regulations Provide Guidance on Base Erosion and Anti-Abuse Tax (BEAT) Proposed regulations provide much anticipated guidance on the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A and related reporting requirements. The regulations are proposed to apply generally to tax years beginning after December 31, 2017, but taxpayers may rely on these proposed […]

Accounting Method Procedures Simplified for Complying with AFS Deadline for All Events Test

Accounting Method Procedures Simplified for Complying with AFS Deadline for All Events Test The IRS will grant automatic consent to accounting method changes to comply with new Code Sec. 451(b), as added by the Tax Cuts and Jobs Act ( P.L. 115-97). In addition, some taxpayers may make the accounting method change on their tax […]

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Author Archive for Steve Grgas

LB&I Withdraws Guidance on Cost-Sharing Arrangement Stock Based Compensation

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

Proposed Regs Provided for Code Sec. 163(j) Limit

Deductions Denied to Medical Marijuana Dispensary

Guidance Issued on Nondeductible Portion of Parking Fringe Expenses and UBTI

Proposed Regulations Provide Guidance on Base Erosion and Anti-Abuse Tax (BEAT)

Accounting Method Procedures Simplified for Complying with AFS Deadline for All Events Test

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