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December 2019 Newsletter

Andy Presti announces, “Shahid Khoja has joined the firm as Tax Manager”. Annemarie Aguanno discusses, “Final Regs Revert Back to Prior Partnership Disguised Sale Rules”.Elias Koumniotes discusses, “Proposed Rules Clarifying Carried Interest Limitation Expected Early 2020, Kautter Says”.

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Andrew Presti

Shahid Khoja has joined the firm as Tax Manager

Presti & Naegele is pleased to announce Shahid Khoja has joined the firm as a Tax Manager Shahid Khoja specializes in international tax, with expertise in the financial services industry, working with clients across the globe and advising on U.S. and international tax issues on cross border transactions. Shahid is an accomplished US and international […]

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Annemarie Aguanno

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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Angelica Farrell

Hopes for Year-End Tax Extenders Package Appear Dwindling

Hopes for Year-End Tax Extenders Package Appear Dwindling Hopes for a year-end tax extenders package appear to be dwindling on Capitol Hill. Tax Extenders Need a Legislative Vehicle Over 30 expired or soon-to-be expired tax breaks known as tax extenders were originally considered a top contender for hitching a ride on a larger, must-pass government […]

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Angelica Farrell

IRS Increases Enforcement Action on Syndicated Conservation Easements, IR-2019-182

IRS Increases Enforcement Action on Syndicated Conservation Easements, IR-2019-182 The IRS has announced a significant increase in enforcement actions for syndicated conservation easement transactions. This is a “priority compliance area” for the agency. Throughout the IRS, coordinated examinations are being conducted in the Small Business and Self-Employed (SB/SE) Division, Large Business and International (LB&I) Division, […]

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Angelica Farrell

IRS Provides Section 199A Safe Harbor for Rental Real Estate

IRS Provides Section 199A Safe Harbor for Rental Real Estate The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to […]

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Angelica Farrell

Proposed Regs Address Terminated S Corporation Distributions

Proposed Regs Address Terminated S Corporation Distributions The IRS has proposed regulations that define an eligible terminated S corporation (ETSC), and provide rules relating to distributions of money by an ETSC after the post-termination transition period (PTTP). The proposed regulations also extend the treatment of distributions of money during the PTTP to all shareholders of […]

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Angelica Farrell

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill “A thumb goes up, a car goes by…” Tax extenders remain a top contender for “hitching a ride” on November’s must-pass government funding bill. Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in […]

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Angelica Farrell

Top Senate Tax Writers Call for Action on SECURE Act

Top Senate Tax Writers Call for Action on SECURE Act Senate Finance Committee (SFC) Chair Chuck Grassley, R-Iowa, and other top Senate tax writers are calling for Senate action on the bipartisan Setting Every Community Up for Retirement Enhancement Secure bill (HR 1994) (SECURE Act). The House-approved, bipartisan retirement savings bill has remained stalled in […]

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Elias Koumniotes

Proposed Rules Clarifying Carried Interest Limitation Expected Early 2020, Kautter Says

Proposed Rules Clarifying Carried Interest Limitation Expected Early 2020, Kautter Says Treasury and the IRS are expected to release proposed rules in “early 2020” that would clarify certain limitations on the carried interest tax break, according to David Kautter, Treasury’s assistant secretary for tax policy. Kautter briefly addressed the proposed regulations’ timeline while speaking at […]

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