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Donald Sager

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized Final regulations relating to the low-income housing tax credit revise and clarify requirements that low-income housing agencies must follow when conducting physical inspections of low-income units and reviewing low-income certifications and other documentation. The regulations finalize previously issued temporary regulations (T.D. 9753, February 25, 2016). Sample […]

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Lisa Varela

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info The IRS has corrected Notice 2019-20, which provided a waiver of penalties under Code Secs. 6722(failure to furnish correct payee statements) and 6698 (failure to file partnership return) for certain partnerships that file and furnish Schedules K-1 to Form 1065 without reporting negative tax basis capital account […]

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Lisa Varela

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss Final regulations have been issued on transactions of U.S. taxpayers that have qualified business units (QBUs) with functional currency other than the U.S. dollar. Specifically, the final regulations: cover combinations and separations of QBUs subject to Code Sec. 987 (Reg. 1.987-2 […]

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Steve Grgas

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income

Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income Medicaid waiver payments were earned income, even though IRS Notice 2014-7 treated them as “difficulty of care” foster care payments that were excluded from gross income. The Tax Court held that excluding the payments from earned income would improperly deny the […]

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Lisa Varela

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception Proposed regulations provide rules on the attribution of ownership of stock or other interests for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The proposed […]

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Lisa Varela

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest Highly anticipated proposed regulations have been issued on the withholding required with respect to the disposition of certain partnership interests. The proposed regulations affect certain foreign persons that recognize gain or loss on the disposition of an interest in a partnership that is […]

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Tracy Tasch

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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Lisa Varela

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon Senate tax writers on Capitol Hill continue to discuss bipartisan retirement savings bills as the House gears up for a vote on a related tax measure. The Senate Finance Committee (SFC) held a May 14 hearing during which lawmakers on both sides […]

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May 2019 Newsletter

Wayne Naegele takes a look at, “Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses”. Annemarie Aguanno discusses, “House Approves Bipartisan IRS Reform Bill”. Sal Russo discusses, “CFC Partners Required to Increase E&P for Subpart F Inclusions”.

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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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