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Salvatore Russo

CFC Partners Required to Increase E&P for Subpart F Inclusions

CFC Partners Required to Increase E&P for Subpart F Inclusions The upper-tier controlled foreign corporation (CFC) partners of a domestic partnership were required to include in gross income their distributive share of income inclusions under subpart F from lower-tier CFCs, and increase earnings and profits (E&P) by the same amount. Regulations under Code Sec. 964provided preliminary […]

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Thomas Zanata

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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Thomas Zanata

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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Thomas Zanata

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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Annemarie Aguanno

House Approves Bipartisan IRS Reform Bill

House Approves Bipartisan IRS Reform Bill The House on April 9 approved by voice vote a bipartisan, bicameral IRS reform bill. The IRS bill, which now heads to the Senate, would redesign the IRS for the first time in over 20 years. IRS Reform The Taxpayer First Act of 2019 (HR 1957), as amended, cleared […]

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Wayne Naegele

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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Thomas Zanata

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams The IRS has provided a safe harbor for professional sports teams to avoid the recognition of gain or loss when trading players and/or draft picks. Under the safe harbor provision, the traded player’s contract or the traded draft pick would have […]

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April 2019 Newsletter

Donald Sager discusses, “Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info”. Elias Koumniotes discusses, “IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance”. Andy Presti takes a look at, “Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties”.

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Andrew Presti

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 […]

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Elias Koumniotes

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance New IRS guidance fills in several more pieces of the Code Sec. 199A passthrough deduction puzzle. Taxpayers can generally rely on all of these new final and proposed rules. Final Regulations The final regulations in T.D. 98xx_1 largely adopt the proposed regulations in NPRM REG-107892-18 (August 16, 2018), but […]

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