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Author Archive for Thomas Zanata

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Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation Proposed regulations would provide guidance on the inclusion of income and deduction items in the calculation of built-in gains and losses under Code Sec. 382(h). The proposed regulations would: simplify the application of Code Sec. 382; provide more certainty to taxpayers in determining […]

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Final Regulations Amend Hardship Distribution Rules from Section 401(k) Plans

Final Regulations Amend Hardship Distribution Rules from Section 401(k) Plans The IRS has issued final regulations that amend the rules relating to hardship distributions from Code Sec. 401(k) plans. The final regulations are substantially similar to the proposed regulations. Further, plans that complied with the proposed regulations satisfy the final regulations as well. The regulations […]

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Proposed Regulations Released on Applicable Financial Statement for All-Events Test

Proposed Regulations Released on Applicable Financial Statement for All-Events Test For a taxpayer using an accrual method of accounting, the all events test is not met for item of gross income any later than when is included in revenue on an applicable financial statement (AFS) or other financial statement specified by the Treasury Secretary. How […]

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Automatic Accounting Change Procedures for All Events Test and Advance Payment Deferral

Automatic Accounting Change Procedures for All Events Test and Advance Payment Deferral Taxpayers may use the automatic consent procedures to change accounting methods to comply with the recent proposed regulations described above. Rev. Proc. 2018-31, I.R.B. 2018-22, 637, is modified. The proposed regulations provide rules for: inclusion in gross income under the all events test […]

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Proposed Regulations Update Exempt Organization Reporting Requirements; Penalty Relief Provided

Proposed Regulations Update Exempt Organization Reporting Requirements; Penalty Relief Provided Amendments to have been proposed to update the information reporting regulations under Code Sec. 6033, which generally apply to organizations exempt from tax under Code Sec. 501(a). The proposed regulations reflect statutory amendments and certain grants of reporting relief announced through guidance that has been […]

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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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