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Donald Sager

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

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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Lisa Varela

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments

Proposed Regulations on Reporting Life Insurance Policy Sales and Death Benefit Payments The IRS has issued proposed regulations on the information reporting requirements under Code Secs. 101(a)(3) and 6050Y, added by the Tax Cuts and Jobs Act ( P.L. 115-97). The regulations are to apply to reportable life insurance policy sales made, and reportable death benefits paid, after December […]

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Lisa Varela

National Taxpayer Advocate Nina Olson Announces Retirement

National Taxpayer Advocate Nina Olson Announces Retirement Nina E. Olson, the National Taxpayer Advocate (NTA), has announced her decision to retire this summer from the esteemed NTA position at the IRS. Olson has served as taxpayers’ “voice” within the IRS and before Congress for the last 18 years. Olson will retire from the position of NTA on […]

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March 2019 Newsletter

Annemarie Aguanno discusses, “IRS Postpones Canceling Tax Transcript Faxing Service After Grassley, Wyden Urge Delay”. Steve Grgas discusses, “Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties”. Tom Zanata takes a look at, “Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits”.

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Thomas Zanata

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations are in response to changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), […]

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Brian Whelan

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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Steve Grgas

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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Brian Whelan

Senators Introduce Bipartisan Craft Beverage Modernization and Tax Reform Bill

Senators Introduce Bipartisan Craft Beverage Modernization and Tax Reform Bill Senators have introduced a bipartisan bill specifically tailored to reduce excise taxes and regulations for the U.S. craft beverage industry. The bill aims to promote job creation and permanently reduce certain taxes and compliance burdens. Craft Beverage Tax Reform The Craft Beverage Modernization and Tax […]

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Brian Whelan

Opportunity Zone’s Tax Writers, Stakeholders Criticize IRS’s 50-Percent Locational Rule

Opportunity Zone’s Tax Writers, Stakeholders Criticize IRS’s 50-Percent Locational Rule The IRS’s proposed 50-percent gross income locational rule on the active conduct of Opportunity Zone businesses is garnering criticism from stakeholders and lawmakers alike. The IRS released proposed regulations, NPRM REG-115420-18, for tax reform’s Opportunity Zone program last October. 50-Percent Locational Rule Many stakeholders have urged […]

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