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Author Archive for Thomas Zanata

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Final Regs Address CPEO Requirements, Responsibilities

Final Regs Address CPEO Requirements, Responsibilities Final regulations provide requirements that a person must satisfy to become and remain a certified professional employer organization (CPEO), as well as the CPEO’s federal employment tax liabilities and other obligations. CPEOs Some employers contract with PEOs to complete and file tax returns, pay and withhold employment taxes on […]

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Final Regulations Reduce Section 956 Income Inclusions by Domestic Corporations Owning CFC Stock

Final Regulations Reduce Section 956 Income Inclusions by Domestic Corporations Owning CFC Stock Final regulations reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The regulations are intended to ensure that Code Sec. 956 is applied consistently with the participation exemption system under Code Sec. 245A. Subpart F Rules Under the […]

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Temporary Regulations Limit Application of Participation DRD To Prevent Tax Avoidance

Temporary Regulations Limit Application of Participation DRD To Prevent Tax Avoidance Newly issued temporary regulations limit the application of the Code Sec. 245A participation dividends received deduction (the participation DRD) and the Code Sec. 954(c)(6) exception in certain situations that present an opportunity for tax avoidance. The temporary regulations also provide related information reporting rules under Code Sec. 6038. Participation […]

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Final and Proposed Regs on GILTI-Related Matters

Final and Proposed Regs on GILTI-Related Matters Final regulations address the global intangible low-taxed income (GILTI) provisions of Code Sec. 951A. The final regulations retain the basic approach and structure of the proposed regulations published on October 10, 2018. The final regulations address open questions and comments received on the proposed regulations. Final regulations on the […]

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Proposed Rules Explain 199A Deduction for Cooperatives and Patrons

Proposed Rules Explain 199A Deduction for Cooperatives and Patrons Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons: Proposed regulations provide detailed rules for coop patrons and specified cooperatives to calculate the deduction. A proposed revenue procedure provides three methods for specified cooperatives to […]

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Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

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Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

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Bipartisan House Bill Aims to Fix “Retail Glitch”

Bipartisan House Bill Aims to Fix “Retail Glitch” A bipartisan House bill has been introduced that would fix a GOP tax law drafting error known as the “retail glitch.” The House bill, having over a dozen co-sponsors, is a companion measure to a bipartisan Senate bill introduced in March. Immediate Expensing The Restoring Investment in Improvements Act […]

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