Final Regulations Issued on CFC Related Person Rules, Active Trade or Business Exception

Final Regulations Issued on CFC Related Person Rules, Active Trade or Business Exception Final 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 regulations also […]

IRS Releases Final and Proposed BEAT Regulations

IRS Releases Final and Proposed BEAT Regulations The IRS has issued final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A. The BEAT is a minimum tax that certain large corporations must pay on certain payments made to foreign related parties, and was added by the Tax Cuts and […]

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final […]

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on Cost-Sharing Arrangement Stock Based Compensation The IRS Large Business and International Division (LB&I) has withdrawn its directive to examiners that provided instructions on transfer pricing issue selection related to stock based compensation (SBC) in cost sharing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 […]

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Author Archive for Steve Grgas

Final Regulations Issued on CFC Related Person Rules, Active Trade or Business Exception

IRS Releases Final and Proposed BEAT Regulations

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

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

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