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Author Archive for Wayne Naegele

wnaegele

Advance Payment Proposed Regulations Released

Advance Payment Proposed Regulations Released Proposed regulations provide rules for accrual method taxpayers who receive advance payments. The proposed regulations include provisions affecting both taxpayers both with and without applicable financial statements (AFS), and describe and clarify the statutory requirements of Code Sec. 451(c). Similar to Rev. Proc. 2004-34The proposed regulations include many provisions similar […]

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wnaegele

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses Proposed regulations address gains that may be deferred when taxpayers invest in a qualified opportunity fund (QOF). Taxpayers may generally rely on these new proposed regulations. The IRS has also requested comments. The proposed regulations also withdraw and replace placeholder provisions in an earlier set […]

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wnaegele

Wayfair decision and impacts on your business

Wayfair decision and impacts on your business On June 21, 2018, the Supreme Court of the United States handed down a historic decision in the sales and use tax nexus case South Dakota v. Wayfair, Inc. The 5-4 ruling overturns physical presence standards upheld in previous cases, such as Quill Corp. v. North Dakota (1992) […]

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wnaegele

Senate, House Lawmakers Introduce Bipartisan Historic Rehabilitation Credit Bill

Senate, House Lawmakers Introduce Bipartisan Historic Rehabilitation Credit Bill A bipartisan group of House and Senate lawmakers have introduced companion Historic Rehabilitation Tax Credit (HTC) bills. The measure aims to strengthen the HTC by encouraging investment and minimizing administrative burdens, according to the lawmakers. Rehabilitation Credit As amended by the Tax Cuts and Jobs Act […]

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wnaegele

ABA Section of Taxation Writes Hatch, Wyden About IRS Reform

ABA Section of Taxation Writes Hatch, Wyden About IRS Reform The American Bar Association (ABA) Section of Taxation has expressed concerns to top Senate tax writers about certain congressional IRS reform efforts. The ABA Section of Taxation sent a June 6 letter to Senate Finance Committee (SFC) Chairman Orrin G. Hatch, R-Utah and ranking member […]

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wnaegele

Railroad Stock Options Are Not Money Remuneration Under RRTA

Railroad Stock Options Are Not Money Remuneration Under RRTA The U.S. Supreme Court has determined that nonqualified employee stock options are not taxable compensation under the Railroad Retirement Tax Act (RRTA). The term “money remuneration” in the Act unambiguously excludes “stock.” Background Several railroads filed a refund claim for overpaid Railroad Retirement taxes. The railroads claimed they overpaid […]

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wnaegele

Indian Gaming Income Distributions Were Not Excludible General Welfare Payments

Indian Gaming Income Distributions Were Not Excludible General Welfare Payments A member of the Miccosukee Tribe of Indians of Florida had to pay federal income tax on distributions of gaming income that she and her family received from the tribe. The payments were taxable income under the Indian Gaming Revenue Act, rather than Indian general […]

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wnaegele

Shareholder Could Not Claim S Corporation’s FICA Tip Credits

Shareholder Could Not Claim S Corporation’s FICA Tip Credits An individual shareholder of an S corporation restaurant operator was not allowed to claim FICA tip credits under Code Sec. 45B that the S corporation did not claim. The shareholder could not unilaterally and retroactively nullify the S corporation’s election to deduct FICA tip taxes. Background The restaurants […]

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wnaegele

Son-of-BOSS Arrangements

Son-of-BOSS Arrangements Participants in the Son of BOSS tax shelter have maintained their perfect losing record in the Tax Court. Thus, another Son-of-Boss deal has failed to produce its promised loss deductions. Son-of-BOSS Arrangements Son-of-BOSS is a variation of a slightly older tax shelter known as the “bond and options sales strategy,” or BOSS. Son-of-BOSS transactions take […]

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